December 4, 2023: NCHR urged CPSC to strengthen protections for scientists against retaliation and instill consequences for violations of the scientific integrity policy.
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December 4, 2023
Docket No. CPSC-2023-0042
The National Center for Health Research (NCHR) appreciates the opportunity to comment on the Consumer Product Safety Commission (CPSC) Draft Scientific Integrity Policy, which was developed in response to the Presidential Memorandum on Restoring Trust in Government Through Scientific Integrity and Evidence-Based Policymaking in January 2021.
NCHR is a nonprofit think tank that conducts, analyzes, and scrutinizes research on a range of health and safety issues. We do not accept funding from companies that make products that are the subject of our work, so we have no conflicts of interest.
We recognize and appreciate the overall plan of this CPSC draft policy; however, much of the guidance is vague or incomplete. We therefore have highlighted below several significant weaknesses that hinder its intended impact on protecting scientific integrity.
This draft policy specifies that the policies surrounding the independent investigations of alleged scientific misconduct will be drafted and completed within one year of the release of this policy. This will include detailed information about the operational criteria for the following, none of which are established in the draft policy:
The absence of these key functions makes it impossible to provide comment on these measures, as most of these measures will be decided upon internally.
We support the statement in the draft policy that “CPSC leadership and management ensure that employees and contractors engaged in scientific activities are able to conduct their work free from reprisal or concern for reprisal.” However, it provides minimal protection beyond that which is already ensured in the Whistleblower Protection Act (WPA). Moreover, this policy does not protect non-whistleblowers who pursue research on controversial matters or publish research that does not support an agency position. We strongly recommend that the policy include some legal protection for scientists that may face retaliation due to differing scientific conclusions.
According to the draft policy, the Executive Director is responsible for ensuring that violators will be “held responsible” but does not provide information about penalties or other consequences for specific types of violations. It is therefore unclear how the policy will deter such violations or ensure that consistent sanctions are applied.
In summary, we strongly support the draft policy as outlined, but encourage the CPSC to revise the draft policy to directly address the gaps discussed above, which are integral to adequately protect scientific integrity.
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