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Policy

EPA libraries in danger

October 23, 2006 | APPEARED IN VOLUME 84, ISSUE 43

Sept. 18, page 16. Vitamin C was incorrectly identified as citric acid. It is ascorbic acid.

Oct. 9, page 12. The article on brain chemistry should have included the following reference information for the work cited: Science 2006, 314, 130.

The Bush Administration is proposing an 80% cut in the library budget of the Environmental Protection Agency. This will result in the closing of all regional office libraries and a substantial reduction in the staff and hours of access to its headquarters library. Whatever the rationale for the decision, it will undermine, rather than foster, environmental science-based decision-making. It may also be contrary to the Jan. 3, 2002, "Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies" issued by the Office of Management & Budget (OMB) to implement the Federal Data Quality Act (FDQA).

EPA regional libraries provide regional staff with ready access to reference volumes, as well as library and database search-and-retrieval services that cannot be made available to individuals cost-effectively. According to Public Employees for Environmental Responsibility (PEER), EPA's own internal analysis estimates that library access saved approximately $7.5 million annually in staff time, three times the $2.5 million annual library budget. More important, the regional libraries are the repositories of documents published by agency and contractor staffs that are paid for by taxpayer dollars and are available nowhere else. PEER notes that there is nothing in the proposed budget to create and disseminate electronic versions of these documents. In addition, the availability of a hard-copy version of each such unique document also ensures that the price of a computer is not a barrier to environmental justice for the poor.

Even if the issue of environmental justice is ignored and the putative annual savings are redirected to a long-term effort to make more of these unique collections accessible electronically, the transfer from a predominantly hard-copy to a predominantly electronic library system must follow the OMB guidelines implementing FDQA. The mandate to maximize the quality, integrity, and utility of the data upon which regulation is based would appear to require that the preparation of an electronic version of each unique regulatory document from each regional library be quality controlled, that the electronic version of each such document be continuously comparable to a certified hard copy of same, and that each such certified hard copy be readily accessible to agency staff, regulated entities, and the public via a regional library.

PEER estimates that more than 50% of EPA staff have signed a letter to Congress asking it to restore the proposed EPA library budget cuts. If the American Chemical Society is committed to the development of environmental regulation based on sound science, then it must support the reversal of this ill-considered decision. It must also call on its sister professional organizations to do likewise.

Larry E. Fink
Boynton Beach, Fla.

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