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ARL Comments on Development of a Federal Scientific Integrity Policy Framework

On March 3, 2022, the White House Office of Science and Technology Policy (OSTP) issued a “Request for Information to Support the Development of a Federal Scientific Integrity Policy Framework.” The Association of Research Libraries (ARL) is pleased to offer the following comments in response to this request.

ARL Comments on Office of Science & Technology Policy (OSTP) Request for Information on the Development of a Federal Scientific Integrity Policy Framework

April 4, 2022

Thank you for the opportunity to comment on the development of a Federal Scientific Integrity Policy Framework. The Association of Research Libraries (ARL) applauds OSTP’s leadership on the importance of scientific integrity policies and the White House’s broad consultations with stakeholders and communities to make access to federally funded research more inclusive. The prior consultations, leading to publication of Protecting the Integrity of Government Science: A Report by the Scientific Integrity Fast-Track Action Committee of the National Science and Technology Council (January 2022), addressed strengthening trust in the federally funded scientific enterprise, and trust in the evidence needed to make decisions that affect our health, climate, and social, political, and economic well-being. In publishing its report, the Fast-Track Action Committee wrote that it “seeks continued meaningful community engagement that will allow those who are most vulnerable, underrepresented, and impacted by Federal Government policy decisions to have a voice in its deliberations and help strengthen trust in government through decision-making that is guided by science.” ARL member libraries are community-engaged institutions; they are trusted partners to their institutional researchers, and can provide channels of communication for their broader communities to engage with federally funded research and the policies that govern that enterprise.

The following comments address the OSTP request for information from the perspective of library and archives research and practice with respect to digital-asset management and preservation, artificial intelligence and machine learning, and metadata interoperability standards. These comments also incorporate research library principles of accessibility; patron privacy; education and lifelong learning; civic education; diversity, equity, and inclusion; and social responsibility. ARL works at the intersection of institutional policy, public policy, and the research and learning community. This includes matters of research integrity and the trustworthiness and persistence of information, including its findability, accessibility, interoperability, and reusability.

  • Information is requested on how scientific integrity policies at Federal agencies and other components of the Executive Branch can be developed or updated to address important and emergent issues of our time, including: (1) Diversity, equity, inclusion, and accessibility, which are essential to advancing the conduct, communication, and use of science, ensuring the equitable delivery of government programs, and improving equitable participation in science by diverse communities across the Nation; (2) New technologies, such as artificial intelligence, machine learning, and the lack of transparency and potential for bias in computer algorithms and associated data; (3) Emerging modes of science, such as citizen science and community-engaged research; and (4) Coordination with related policy domains, such as open science and data; quality guidelines for data and information that agencies release; promotion of safe, equitable workplaces free from harassment and discrimination; and protection of research security and responding to research misconduct.

In the following sections, ARL recommends that, with respect to:

Diversity, equity, inclusion, and accessibility

  • Agencies work with advocacy and community organizations for underrepresented groups, including faculty engaged in community-based research, when making policies that involve research for or about those communities
  • Stakeholders, in developing data-access and data-sharing arrangements, include individuals or groups whose data are being collected in the governance of that data, such as through the use of the CARE principles1
  • Agencies work with publishers, scholarly societies, and others pledging to combat racism in science, building on the recognition by OSTP2 and the National Academies of Sciences, Engineering, and Medicine3 that pervasive sexual harassment poses a threat to scientific integrity
  • Accessible technologies and outputs be required in federal research-funding programs
  • Agencies work with such organizations as the Committee on Publication Ethics (COPE), institutions, and scholarly societies in the adoption and application of ethical research guidelines

Artificial intelligence (AI)/Machine learning (ML)

  • Stakeholders provide access to data and AI/ML algorithms and capabilities
  • Privacy considerations are incorporated into AI and ML processes and privacy risks are mitigated
  • Define a taxonomy of AI and ML that connects to OSTP’s scientific integrity policy
  • OSTP and other agencies continue to work with the National Institute of Standards and Technology (NIST) to develop the AI Risk Management Framework,4 fully considering the socio-technical needs of AI systems and tools for implementation throughout the software life cycle

Citizen science and community-engaged research

  • Agency policies encourage immediate open-access content and, where feasible, open-source infrastructure, which serves both these emerging modes of science, while protecting privacy
  • OSTP and agencies involve community representation in research development and/or research design, implementation, or communication
  • Engage community partners at significant points in the research process to ensure stakeholder and community alignment, reduce biases, and ensure smooth and socially impactful research outcomes

Coordination with related policy domains

  • Agencies require the use of persistent identifiers (PIDS) and recognize that PIDS, registries, and the connected metadata underlying them are critical to discoverability and provenance5
  • OSTP and agencies work with information standards organizations, research libraries, and other stakeholders in the research/scholarly communication ecosystem to enhance findability, interoperability, and reusability of scientific research and data
  • OSTP and agencies work with institutions, research libraries, and scholarly societies to advance responsible conduct of research programming related to scientific integrity

ARL will continue to partner with higher education associations, our members, federal agencies, scholarly societies, and other stakeholders to advocate for and implement policies to strengthen research integrity.

Thank you for your consideration of these comments.


Mary Lee Kennedy
Executive Director
Association of Research Libraries



1 Stephani Russo Carroll et al., “The CARE Principles for Indigenous Data Governance,” Data Science Journal 19, no. 1 (2020): 43, http://doi.org/10.5334/dsj-2020-043.

2 President’s FY 2021 Budget Request for Research & Development, before the Committee on Science, Space, and Technology, 116th Cong. (February 27, 2020) (statement of Kelvin Droegemeier, Director of the Office of Science and Technology Policy, Executive Office of the President of the United States), https://science.house.gov/imo/media/doc/Droegemeier%20Testimony1.pdf

3 “Sexual Harassment in Academic Science, Engineering, and Medicine,” The National Academies of Sciences, Engineering, and Medicine, accessed April 4, 2022, https://www.nationalacademies.org/our-work/sexual-harassment-in-academia.

4 “AI Risk Management Framework,” National Institute of Standards and Technology, accessed April 4, 2022, https://www.nist.gov/itl/ai-risk-management-framework.

5 John Chodacki et al., Implementing Effective Data Practices: Stakeholder Recommendations for Collaborative Research Support (Washington, DC: Association of Research Libraries, September 2020), https://doi.org/10.29242/report.effectivedatapractices2020.


About the Association of Research Libraries

The Association of Research Libraries (ARL) is a nonprofit organization of 126 research libraries in Canada and the US whose mission is to advance research, learning, and scholarly communication. The Association fosters the open exchange of ideas and expertise; advances diversity, equity, and inclusion; and pursues advocacy and public policy efforts that reflect the values of the library, scholarly, and higher education communities. ARL forges partnerships and catalyzes the collective efforts of research libraries to enable knowledge creation and to achieve enduring and barrier-free access to information. ARL is on the web at ARL.org.

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