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If Scientists are Unmuzzled in the Forest, Do They Make a Sound?

Since late 2018, select federal departments and agencies have started rolling out scientific integrity policies. In this blog post, Matthew MacLeod reflects on the challenges in policy implementation.

Matthew R. MacLeod has been a member of the PIPSC Research (RE) Group Executive since 2009, serving as its President from mid-2015 to mid-2023, and presently as its Treasurer. He served on one of the bargaining teams that negotiated the Scientific Integrity Memorandum of Agreement, as well as on the working group that created the Model Policy on Scientific Integrity.

It has been six years since the Professional Institute of the Public Service of Canada (PIPSC) Research (RE) and Applied Science and Patent Examination (SP) group collective agreements requiring that federal departments and agencies create and maintain scientific integrity policies (SIPs) were signed, and four years since most of them came into force (1 April 2019).

Signed pieces of (mostly virtual) paper are all well and good, but what is happening with these policies? In this blog post, I will identify three areas where implementation of the SIPs appear to be failing researchers, scientists and the public interest.

1. Monitoring of implementation is lagging

Despite the SIP’s emphasis on the principles of transparency and openness, many departments and agencies are remarkably closed about its implementation. As noted in the latest public report on the status of federal SIPs, of the 22 of 25 organizations who have implemented a SIP as required: “no [department or agency] has implemented a monitoring plan that will provide information on the extent to which their SIP has achieved its objectives.” How can a department know that scientific integrity is being realized, if they don’t actually monitor its implementation?

2. Transparency is weak

The report on the status of federal SIPs provides overall counts of how many departments and agencies have implemented certain aspects of the SIP “based on a thorough review of all evidence provided.” That said, the evidence is not made public. Departments and agencies are not named, so the public does not know which departments and agencies have done what. Indeed, not all departments post their SIP publicly, despite the fact that nearly all of them follow the (very public) model SIP, almost word for word.

In the Model SIP, section 6.3 states that “in the absence of clear and compelling reasons for limiting disclosure,” research and scientific information produced by a federal department should be made available to the public in a timely manner, and in keeping with the Government of Canada’s Directive on Open Government. If the Department of National Defence/Canadian Armed Forces’ policy and associated breach procedures are publicly available, what “clear and compelling reasons for limiting disclosure” of the policies and procedures can other departments have? As I will explore in the next section, it may be debatable whether the research information supporting the implementation report belongs to the Office of the Chief Science Advisor or to the subject departments and agencies, but regardless, they would appear to all have duties under their SIPs to disclose the supporting evidence on their implementation status.

3. Seams in breach reporting structure leaves important gaps

A feature of the SIPs created by the original agreement is that each department and agency has its own SIP and associated procedures, rather than there being one overall SIP for the whole public service, or even the core public service. PIPSC’s early experience with situations where scientists and others have filed breaches is that this fact, when combined with the interdepartmental nature of much government science advice, greatly undercuts the ability to investigate potential breaches of the polices.

Consider the structure of environmental assessments required by the 2012 Canadian Environmental Assessment Act, as described here. The lead of the assessment may be one of three federal agencies: the Canadian Environmental Assessment Agency (CEAA), the National Energy Board, or the Canadian Nuclear Safety Commision. Alternatively, it may be led by a review panel of external experts, supported by the CEAA. Further, “[t]he general public, Indigenous peoples, and other governmental agencies participate in the process by contributing comments, knowledge, and feedback. Federal departments and agencies with specific expertise are required to provide information and expert advice that support environmental assessments or review panels.” One can see the issue here: even sticking to the core federal public service in addition to the CEAA, departments like Environment and Climate Change Canada, Fisheries and Oceans Canada, and Natural Resources Canada all have their own SIPs, and depending on the project may be contributing their specific scientific and research expertise. If a scientist or researcher in one of these departments thinks their advice is being misrepresented, miscommunicated, or otherwise interfered with in one or more of the other departments, how is that to be handled through a breach process limited in scope to only their own department?

What can be done?

So where does this leave us? While PIPSC continues to try to work with departments to improve their SIP implementation, the public needs to be engaged for the public good to be met. While unmuzzling government scientists and researchers was free (and arguably even saved the government money on oversight), it is important to remember that funding for federally conducted research has remained largely flat over the last ten years. It is not free to prepare and post complicated datasets for public access, so any money that has been spent on opening data has come out of existing research budgets.

We invite the public and the wider non-governmental sector to ask questions of government departments, their communications staff, and individual researchers and scientists. Ask why the information supporting decisions is not being made public. If you suspect a department is breaching its SIP, ask for their breach policy, and ask to file a breach.

The work of making government decision-making transparent did not end with the signing of the SIPs — it began there.

The Professional Institute of the Public Service of Canada (PIPSC) represents over 15,000 public scientists, engineers and researchers. Our members are experts in everything from rail safety, vaccines, climate change, and water quality to air pollution, farming, fossil fuels, and nuclear energy. Together, we work hard to defend public science. We champion scientific integrity and increased inclusion of women in science.

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