Forwarded from Jeff Green. Please forward to others. For more information about the EPA Union, go to: <>. Contents: 1) URGENT Request 2) Contact information 3) Previous request, for further background On May 6, 2002, we sent out an urgent request for support of the the union that consists of and represents all of the scientists and other professionals at the U.S. Environmental Protection Agency, Headquarters, Washington, D.C. As detailed in that request, NTEU Chapter 280 (previously NFFE, local 2050) is asking for public support for the "principles of scientific integrity" that ultimately determine whether decision-making is an open and transparent process, and truly based on the science that the mission of EPA and our confidence requires, or whether the EPA as an agency is given full rein to act as a buffer zone to scientific accountability. I urge you to act on this request to contact all of your representatives and EPA Administrator Christine Todd Whitman by mail or email at the contact points reproduced below, and to encourage every individual that you can to do the same. I have copied, below, an extremely articulate explanation sent out by Senior Vice President Bill Hirzy today to his colleagues in the EPA that are not members of the headquarters union so that they may more fully understand the need for implementing an enforceable policy that supports scientific integrity and eradicates manipulation of employees to produce flawed data to cover up agency agendas. Please give this request the attention, respect and action that it deserves. ___ jeff Jeff Green National Director Citizens for Safe Drinking Water 1010 University Avenue #52 San Diego, CA 92103 (800) 728-3833 <> From William J. Hirzy, Ph.D. Dear Colleagues: I'm writing this, on behalf of NTEU Chapter 280 and as a 16-year veteran of the research bench, to our colleagues outside the EPA Headquarters region, particularly to those who toil in the laboratory, to explain why we Headquarters scientists consider the Principles of Scientific Integrity so important as a working conditions issue. When I worked as a research and process development chemist in the private sector, I was almost always involved in research work that had a specific, management-directed goal in mind - make a plasticizer that won't mar polystyrene finishes on refrigerators, that won't degrade to produce odors that will affect food flavors - make a non-toxic plasticizer for blood bags that won't migrate into blood lipids, yet forms a stable plasticized container system at all temperatures - develop a manufacturing process for a phosphorus-based flame retardant that won't blow up the plant, yet produces high-quality product at a cost customers will bear, etc., etc. Management never told me to lie about how well a plasticizer performed in an extraction test or whether it marred a test surface. Management never told me to change the yield figures to make process economics look good. They never had to. It is obvious that faking it simply is not an option - as Richard Feynmann put it when he investigated the Challenger disaster - " Mother Nature will not be fooled." Those of us who work at Headquarters mostly don't have the pleasure of working at a research bench, asking Mother Nature questions, observing her answers and then deciding what next to do: publish what we think she is saying, if our confidence in our interpretation is high enough; or go back and ask more questions until our understanding and confidence are sufficient to publish. The way we deal with science at Headquarters is quite different from that ideal. There may be a court-ordered schedule of rule-making facing our Office management, and it might involve setting what amounts to a "safe" exposure level for humans or other species. On occasion, a manager has his or her own idea of what that "safe" level should be, or the manager gets orders from up the line, perhaps even the White House or Capitol Hill, that the "safe" level is some particular value. This is not hypothetical. This has happened and continues to happen. The manager then comes to a staff scientist and says, "This is the safe level that we are going to propose in the Federal Register. Write me a justification for it." What is sometimes overtly stated, sometimes not, is, "And I don't care what the literature says, my bosses have given me instructions on this, and if you want to stay on my good side, and if you want to see some award money, you will craft for me an elegant justification for this 'safe' level." This situation, while not always the norm, does happen. When the literature does not support what management wants to do, it is a gut-wrencher for ethical scientists whose work involves reading the literature, making value judgments about the merits of the published work of other scientists, and writing technical support documents for Agency rule-making (or overseeing contractors who do that). Certain statutes permit management to set "safe" levels based on factors other than the physical and biological sciences, for example, Maximum Contaminant Levels (MCL) for drinking water. MCLs are supposed to be set as close as possible to the Maximum Contaminant Level Goal (MCLG), which is supposed to be based solely on scientific considerations of toxicity, but the MCL can be set at a different level if economic, feasibility or other factors so indicate. We have no quarrel with that situation - it is, after all, what the law passed by Congress and signed by the President and adjudicated by the Courts, mandates - it is a Constitutionally right-on situation, and we are sworn to uphold the Constitution. Where we do have a quarrel, however, is when management orders up a phony MCLG so that a politically dictated MCL will have scientific "cover" We do have a quarrel when management arranges it so that an EPA toxicologist is prevented from attending a pathology review at which all malignant tumors get down-graded so that an economically important pesticide can achieve a lower cancer rating. And when management collects data on indoor air pollutants within its own buildings, conducts and publishes a major survey showing that its own employees were sickened by the pollutants, privately (and to the media) admits that those pollutants made the employees sick - and then disavows these results and statements - all to protect a large industry and avoid "getting involved in lawsuits," do we ever have a quarrel. These are just a few high-profile, real-life examples of what scientific integrity means B or doesn't mean B at Headquarters. We organized this union at Headquarters in the early 1980's to fight just this sort of distorted use of science, which impinges negatively on our working conditions, on our reputations, and ultimately on public health. It took almost two decades and much blood and tears finally to sway one set of senior EPA managers to acquiesce to establishing a set of professional ethics for EPA scientists. Management chose to call it Principles of Scientific Integrity. But the job is not complete. There is no implementation plan for the Principles of Scientific integrity, no agreed upon method of resolving disputes that arise. We have filed two grievances, citing violations of the Principles of Scientific Integrity, and both times management has alleged that the grievance process doesn't reach to enforcing the Principles. We can, and we may yet, test this allegation before an arbitrator, but we are using another method too. <P> Our work with EPA Headquarters employees who have taken ethical stands against distorted science has become public knowledge. Citizens and groups outside the Agency have inquired about our work with these employees and we have responded in ways that were useful to these citizens. When EPA tried to strangle our union in the early 1990's we called upon those citizens for help in fighting off management's attacks B and we were successful in a big way. We have now called upon these citizens again, asking them for help in making EPA see the need to make the Principles of Scientific Integrity more than mere window dressing. This campaign began on May 1, 2002 B how appropriate B and was triggered by the "2+2=7" incident, in which a supervisor told a member of our bargaining unit, "Its your job to support me, even if I say 2+2=7." <P> NTEU Chapter 280 seeks the advice of our fellow employees across the Agency in developing plans to fully implement the Principles of Scientific Integrity, which benefit every ethical EPA employee. Please contact me with your ideas. Thanks in advance. Solidarity, Bill Hirzy, Ph.D. Senior Vice-President ############################# Contact information Dr. Hirzy asks that you contact your representatives immediately. You can identify your representatives if you are not certain who they are, and access all of their contact information, by merely entering your zip code at <> Dr. Hirzy would like to track how this call to action is progressing, especially any responses from your representatives or the EPA administration. You can bcc him or forward your statements and responses to: Bill Hirzy <> Please note that this is not just about fluoridation. It is about the entire foundation of how protective measures are determined and incorporated throughout our entire nation. We suggest old fashioned letters to both Congress and EPA. At EPA, Ms. Whitman has no e-mail address accessible to the public, and Mr. Winn may set his e-mail system to automatically delete messages from citizens, especially if the title line mentions the union or scientific integrity. Your representatives in Congress, however, will not ignore you (even if you use e-mail), and EPA cannot ignore inquiries from Congress. The pressure you bring to bear on EPA through your Senators and Representative will be supremely valuable. EPA's mailing address is: U.S. EPA, 1300 Pennsylvania Ave., N.W., Washington, D.C. 20460. If you wish to e-mail Mr. Winn anyway, his e-mail address is: <> You may wish to send a copy of any e-mail to Mr. Winn also to this address: <>. Mr. Sharfstein is the head of labor relations at EPA.