KOSEN 한인과학기술자네트워크

The policies and procedures developed by the staff office to ensure the independence of the Board's peer reviewers and the balancing of viewpoints represented on each panel have limitations that reduce their effectiveness. Specifically, prior to our review, the staff office did not determine whether the subjects to be reviewed were "particular matters" as defined by the financial conflict-of-interest statute - the necessary first interest under the statute. Moreover, the staff office has not routinely ensured that panelists' financial disclosures are complete and that it has obtained sufficient information to evaluate potential conflicts of interest. These shortcomings exist, in part, because of the staff office's uncertainty regarding what constitutes a "particular matter" In addition, the staff office has not systematically requested certain information that is pertinent to assessing the independence and overall balance of viewpoints represented on the panel - such as previous public positions the panelists have taken on the matter being reviewed - until the first meeting, when the panelists have already been selected. These and other shortcomings could reduce the effectiveness of the Board overall if they contribute to its being perceived as biased and could inadvertently expose some panelists to violations of federal conflict-of-interest laws. We are making recommendations to the EPA Administrator to better address potential conflicts of interest and support the development of balanced panels. The staff office's policies and procedures for providing the public with information on the background of the Board's peer review panelists do not adequately inform the public about the points of view represented on the panels. While the staff office does provide the public with information about the panelists' primary employment, this information alone is often insufficient to understand the perspectives and potential biases of the panelists because they may have other significant affiliations. For this reason, the staff office developed a voluntary disclosure session, conducted at the panel's first public meeting, during which panelists discuss their background associated with the issue at hand to better inform the public about their viewpoints. However, because the disclosures are not systematically recorded in the minutes of the meetings, in many cases only the members of the public who are able to attend the public meetings have access to the disclosures. In addition, our review of the minutes of the four panels showed that some of the disclosures raised more questions or were too vague to be of use - such as a panelist's disclosure that he had made public pronouncements, without clarifying their relationship to the matter at hand. We are making recommendations to the EPA Administrator designed to ensure that the public is adequately informed of panelists' points of view