Download PDF
October 31, 2011

SAB Announces Initiatives Intended to Enhance Public Involvement in Advisory Activities

Bergeson & Campbell, P.C.

The U.S. Environmental Protection Agency (EPA) Science Advisory Board (SAB) recently posted a list of fiscal year (FY) 2012 initiatives intended to enhance public involvement in advisory activities. According to the SAB website, in response to suggestions received at a June 1, 2011, session on public involvement, the SAB Staff Office developed additional practices to enhance public involvement in activities of the SAB, Clean Air Scientific Advisory Committee (CASAC), and Advisory Council on Clean Air Compliance Analysis (Council). As you will see, the changes reflect favorably on the nature and quality of the public comments. The changes will enhance the transparency of the SAB process. The additional practices include:

  • Federal Register notices to clarify that public comments are welcome on all technical materials prepared for or by an advisory committee, including the charge to the committee;
  • The Staff Office and advisory committees will not accept a charge from EPA that unduly narrows the scope of an advisory activity;
  • Time will be reserved on meeting agendas for committee members to discuss the charge;
  • Following public comments at advisory committee meetings, Chairs will ask committee or panel members if they have clarifying or follow-up questions for public presenters;
  • Chairs will offer a second brief opportunity for additional clarifying remarks from agency representatives or members of the public later in the meeting, as the committee or panel deliberates on responses to the charge questions;
  • Advisory committee reports will acknowledge scientific information from the public that was helpful in forming the committee’s conclusions and recommendations; and
  • Advisory committee reports will continue to focus on scientific and technical — rather than policy — issues, although reports may discuss the policy context and may note policy implications of technical findings.

SAB reviews have received criticism in the past, including the SAB workgroup charged with reviewing EPA’s draft Toxicological Review of Inorganic Arsenic: In Support of the Summary Information on the Integrated Risk Information System (IRIS). Criticisms of the workgroup included its narrow focus on EPA’s charge, rather than reviewing the science used in EPA’s assessment.