Getting to Green - Research Progress on Environmental Health and Safety Aspects of Engineered Nanomaterials - page 68

progress was deemed to have been made in the “continued separate tracking and reporting of EHS
research activities and funding” (NRC 2012, p. 183), so this indicator was yellow.
To move those indicators toward green, actual or perceived conflicts that arise from the NNI's
dual mission could be addressed through structural and managerial changes—driven by changes in the
NNI's authorizing statute or by changes that the NNI and its participating agencies could implement
themselves. Such changes do not seem to be forthcoming; indeed, in its 2013 budget supplement (NSET
2012b), the NNI noted that such actions are “unlikely or not needed”. The committee continues to believe
that the NNI writ large would benefit from a clearer separation of authority and accountability for its EHS
research enterprise. It would not only advance stakeholder trust and confidence in the seriousness of the
NNI's commitment to responsible development, especially the integral importance of its EHS research
mission, but would help to address the need for better integration and coordination of EHS research
throughout the NNI. The committee urges the NNI to review and reconsider the variety of models,
mechanisms, and managerial processes noted in the committee's first report. Until such changes in
structure, management, and budgetary processes are made, greater transparency will be key in getting to
green.
Even within its current remit, greater transparency can help to address concerns about possible
conflicts of interest and real or perceived bias within the NNI research community. 4 The NNI has already
made some progress in enhancing transparency for its EHS research, for example, by improving the
tracking and reporting of EHS research activities and funding and by providing narrative information on
agency-specific EHS research activities and projects in the NNI supplement to the president's FY 2013
budget. Further efforts to enhance the timeliness, specificity, and accessibility of information about EHS
research projects are needed, including development of clearer guidance on how agencies should
differentiate between research directly relevant to EHS risk and applications-oriented research with EHS
implications.
Transparency and trust can be further advanced through creation of and adherence to strong
scientific-integrity policies at the agency level. Following a presidential memo on the topic, OSTP issued
guidelines for scientific-integrity policies in 2010 (Holdren 2010), and most departments have developed
policies and plans in response. 5 The NNI should periodically review the scientific-integrity policies of its
participating agencies to ensure continued attention and adherence to the key principles of scientific
integrity—a cornerstone of public trust in the scientific enterprise of public agencies.
The NSET, the NNCO, and NNI agencies should explore additional mechanisms to foster
transparency and thus minimize and manage any concerns about conflicts of interest and bias. For
example, the NNCO or NNI agencies could create an ombudsman position to receive, investigate, and
resolve complaints or concerns about bias and conflicts of interest in the NNI's research portfolio. The
NNCO could also develop and disseminate best practices for identifying, managing, and preventing
conflicts of interest and bias in the planning, conduct, and reporting of research—especially for entities
engaged in research on both nanoscience applications and their EHS implications. Identification of best
practices, with appropriate checks and balances, should be informed by input provided through a
multistakeholder process that includes workers, consumers, health and environmental NGOs, large and
small businesses, and researchers in the public and private sectors. Attention to frequency, timeliness,
substance, and inclusivity of stakeholder engagement activities can also enhance trust and transparency.
4 For definitions of conflict of interest and bias, see Appendix B in the Keystone Center's report from the
Research Integrity Roundtable, Improving the Use of Science in Regulatory Decision-making: Dealing with Conflict
of Interest and Bias in Scientific Advisory Panels and Improving Systematic Scientific Reviews (Keystone Center
2012). For hypothetical examples of conflict of interest and bias, see Appendix 1 in the Bipartisan Policy Center
report Improving the Use of Science in Regulatory Policy (Bipartisan Policy Center 2009).
5 For an assessment of and link to agency scientific-integrity policies, see UCS (2012).