Dr. E. William Colglazier
September 8, 2000
Executive Officer
The National Academies
2101 Constitution Avenue, N.W.
Washington, D.C. 20418

re: NAS Committee Disclosure Policies

At our meeting of July 5th with you and several of your colleagues, we reiterated the concerns expressed to you in our letter of May 22, 2000, regarding the NAS’s disclosure policies governing conflicts of interest (or competing interests) of advisory committee members. During that meeting, you will recall, we pointed out the problems created by the differing disclosure policies the NAS employs — i.e., whether a committee is government-funded or whether the subject matter of a committee inquiry might be deemed “controversial.”

Today, we write once again to express our concerns, this time regarding the Committee on Environmental Impacts Associated with Commercialization of Transgenic Crops (EIACTC), a government-funded committee (so Mr. Kim Waddell informed us).

Unlike the Committee on Genetically Modified Pest Protected Plants (GMPPP), the information provided on the current NAS website for the EIACTC committee does not include a conflicts-of-interest or competing-interest disclosure statement for each member (e.g., “Dr. X receives research funds from Y Corporation”). Thus, the current GMPPP website for Dr. Fred Gould notes: “Dr. Gould receives research funds from USDA, NSF, Monsanto, and Mycogen.” (Monsanto and Mycogen are major producers of transgenic seeds.) By sharp contrast, the current NAS website for the EIACTC committee, which Dr. Gould chairs, has no such disclosure.

Furthermore, nowhere on the NAS website for the EIACTC is it disclosed that Professor Alan McHughen has received research funding from Rhone-Poulenc, DuPont, AgrEvo, Western Grains Research Foundation, NSERC, and NRC-Industry. (We also note that Professor Ronald L. Phillips has received research funding from the Quaker Oats Company.) The only conflicts-of-interest disclosure offered on the EIACTC website concerns Professor Brian Larkins.

Both of the above-mentioned committees deal with similar issues and, we suspect, their reports could be equally controversial. Nonetheless, the very kind of disclosure that is deemed .important for one committee is apparently regarded as unimportant for another. Ironically, the standard of disclosure was less for the government-funded EIACTC committee than for the non-government-funded GMPPP committee, even though we had understood from the July meeting that the NAS-NRC is required to disclose conflicts of interest for all government-funded committees. We are puzzled by the inconsistency.

As we noted in our July 5, 2000 meeting with you and your colleagues, failure to fully disclose all relevant conflict of interest information can only detract from the credibility of NAS reports and from its reputation.

We understand that Dr. Richard Bissell of the Committee on Science, Engineering, and Public Policy is conducting panel discussions regarding conflicts of interest, specifically in response to Secretary Shalala’s concerns. In light of that, and also the matters we mentioned in our letter of May 22^nd, it seems all the more important for the NAS to adopt a uniform and meaningful policy of full disclosure. In short, we again urge the NAS to adopt the recommendations we have submitted to it.

We appreciate your consideration and await your response.

Ronald Collins
Director,
Integrity in Science Project