Implementation Remains Uneven

Two years after EPA established its peer review policy, implementation is still uneven. The Council’s interim report pointed out that “although peer review is widely used and highly regarded, it is poorly understood by many, and it has come under serious study only in recent years.” Although we agree that the issues EPA and others have raised may warrant further consideration, we believe that EPA’s uneven implementation is primarily due to (1) confusion among agency staff and management about what peer review is, what its significance and benefits are, and when and how it should be conducted and (2) ineffective accountability and oversight mechanisms to ensure that all products are properly peer reviewed by program and regional offices. EPA’s Actions to Improve the Peer Review Process

EPA has recently taken a number of steps to improve the peer review process. According to the Deputy Administrator, this expanded assessment and verification process will help build accountability and demonstrate EPA’s commitment to the independent review of the scientific analyses underlying the agency’s decisions to protect public health and the environment. Similarly, the efforts aimed at improving the accountability and oversight of peer review fall short in that they do not ensure that each office and region has considered all relevant products for peer review and that the reasons are documented when products are not selected. This process would provide upper-level managers with the necessary information to determine whether or not all products have been appropriately considered for peer review. We have grouped the cases below according to whether (1) EPA’s peer review policy was followed, (2) the policy was not fully followed, or (3) a peer review was not conducted but should have been. “The importance of this . The agency plans to have the impact statement peer reviewed.
Why GAO Did This Study

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.

What GAO Found

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.