Create science advisory boards. (1) The President should require that heads of regulatory agencies that conduct rulemaking or other proceedings that depend heavily on scientific information and judgments create a science advisory board or explain why such a board is not needed. Agencies which face scientific issues in research and development rather than regulatory contexts may have other options such as the Federal Coordinating Council for Science, Engineering and Technology (FCCSET) (proposed for reconstitution as the National Science and Technology Council by NPR).[Endnote 27] Furthermore, regulatory agencies all have differences that may lead to different approaches to considering or creating such a board. FDA's reliance on scientific advisory committees led to a small overarching board, while EPA has an 80-member board with 10 committees. But all agencies, especially those with regulatory mandates involving risk-related questions, should consider creating a board that meets their specific needs.[Endnote 28] Agencies with less frequent or less pressing scientific issues may wish to use established boards in other agencies. A fee-for-service program should be developed to foster this approach. Moreover, agency science boards should be linked to one another, perhaps under the sponsorship of the Regulatory Coordinating Group or the President's Office of Science and Technology Policy (OSTP).[Endnote 29] Such a linkage will facilitate synergy among the boards and will help agencies identify cutting-edge and other issues that would benefit from review by a quasi-independent board of outside scientific experts. Agencies that do create such boards need to pay attention to their staff support as well.[Endnote 30] They need not be expensive propositions. Although EPA's mega-board has an annual budget of $1.7 million, the charter for the FDA Board estimates the annual cost of travel, compensation, and staff support to be less than $100,000. Both of these amounts seem like bargains, given the tremendous cost implications of EPA and FDA scientific decisions. Endnotes 27. Federal Coordinating Council for Science, Engineering and Technology (FCCSET) was established in 1976 along with the White House Office of Science and Technology Policy (OSTP). According to the Carnegie Commission's study, "FCCSET's influence has varied over the past decade." Carnegie Commission report, supra, note 6 at p. 40. NPR is recommending that the President issue an executive order and propose legislation to reconstitute FCCSET into the National Science and Technology Council, giving it a broader role in setting since and technology policy. See NPR Accompanying Report, National Science Foundation/Office of Science and Technology Policy, "NSF01: Strengthen Coordination of Science Policy." 28. This follows the recommendation of the 1983 National Academy of Sciences report, Risk Assessment in the Federal Government: Managing the Process (May 1983), Recommendation 3, p. 156. See also the proposal by the American Industrial Health Council (AIHC) that the Occupational Safety and Health Administration (OSHA) create a science advisory committee, AIHC Proposal for an Ad Hoc OSHA Science Advisory Committee (August 28, 1990). 29. The Carnegie Commission report suggested that OSTP play a leading role in policy decisions involving scientific and regulatory decisions. Carnegie Commission, p. 47. 30. With respect to staffing, Bruce Smith has argued: At a minimum the necessary elements seem to include the following: a full-time secretariat consisting of several persons; additional staff support, preferably drawn from the rest of the agency, for each separate task group established; an adequate budget, including some funds for travel, consultants, and contract research; and a career pattern within the agency that makes a support role to the advisory board a desirable assignment (both for promising younger officials and for senior people). The advisory board's secretariat should comprise persons with enough stature to permit easy interaction with other senior executives in the agency (both appointive and career) and with the committee members. Smith,The Advisers, p. 205.
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