Peer Review:

EPA's Implementation Remains Uneven

RCED-96-236: Published: Sep 24, 1996. Publicly Released: Oct 9, 1996.

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Peter F. Guerrero
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Pursuant to a congressional request, GAO reviewed the Environmental Protection Agency's (EPA): (1) progress in implementing its peer review policy; and (2) efforts to improve the peer review process.

GAO found that: (1) although EPA has made progress in implementing its peer review policy, after nearly 2 years, implementation remains uneven; (2) while GAO found cases in which the peer review policy was followed, GAO also found cases in which important aspects of the policy were not followed or peer review was not conducted at all; (3) two primary reasons for this unevenness are: (a) confusion among agency staff and management about what peer review is, what its significance and benefits are, and how and when it should be conducted; and (b) inadequate accountability and oversight mechanisms to ensure that all relevant products are properly peer reviewed; (4) EPA officials readily acknowledged this uneven implementation and identified several of the agency's efforts to improve the peer review process; (5) because of concern about the effectiveness of the existing accountability and oversight mechanisms for ensuring proper peer review, EPA's Deputy Administrator recently established procedures to help build accountability and demonstrate EPA's commitment to the independent review of the scientific analyses underlying the agency's decisions; (6) these efforts are steps in the right direction; however, educating all staff about the merits of and procedures for conducting peer review would increase the likelihood that peer review is properly implemented agencywide; and (7) furthermore, by ensuring that all relevant products have been considered for peer review and that the reasons for those not selected have been documented, EPA's upper-level managers will have the necessary information to ensure that the policy is properly implemented.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: In response to this recommendation, EPA issued its Peer Review Handbook in February 1998 and provided peer review training in May 1998. The handbook provides guidance on planning, conducting and documenting peer review, and developing training materials to ensure that managers and staff are aware of their peer review responsibilities. It also expands the discussion of the definitions of peer review, peer input, public comment, and stakeholder involvement. According to EPA, the handbook provided the basis for the training provided to all peer review coordinators. In addition to providing an overview of the handbook, the training focused on the role, benefits and need for peer review, the peer coordinator's role, desk aids for decisionmakers, peer review leaders and coordinators and the peer review tracking system.

    Recommendation: To enhance the quality and credibility of its decisionmaking through the more widespread and consistent implementation of its peer review policy, the Administrator, EPA, should ensure that staff and managers are educated about the need for and benefits of peer review; the difference between peer review and other forms of comments, such as peer input, stakeholders' involvement, and public comment; and their specific responsibilities in implementing the policy.

    Agency Affected: Environmental Protection Agency

  2. Status: Closed - Implemented

    Comments: EPA has made policy changes to expand the list of products nominated for peer review and to provide explanations for why individual products are not nominated for peer review. In 1997, EPA: (1) implemented an agency-wide annual update process for the candidates for peer review to ensure that all products are listed; (2) implemented a peer review product-specific audit program; (3) conducted a management assessment of the processes used to decide whether to review products; and (4) tasked the Office of Research and Development with providing feedback to managers on the completeness of the list of candidates. As a result of these initiatives, all technical and scientific products are put on the list of candidates considered for peer review. Also, program managers now include on a separate listing products not considered for peer review.

    Recommendation: To enhance the quality and credibility of its decisionmaking through the more widespread and consistent implementation of its peer review policy, the Administrator, EPA, should expand the current list of products nominated for peer review to include all major products, along with explanations of why individual products are nominated for peer review.

    Agency Affected: Environmental Protection Agency


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