On July 18, 2025, the U.S. Environmental Protection Agency (EPA) rolled out the “reorganization plan” for its Office of Research and Development (ORD). The stated goal of the plan is to reduce budget expenditures, improve “science,” and have EPA’s research activities better support the work of the media offices, including the Office of Water (OW), Office of Air and Radiation (OAR), and Office of Chemical Safety and Pollution Prevention (OCSPP). The EPA press release refers to the effort as a continuation of “comprehensive restructuring” that includes a reduction in force (RIF) for the ORD and a subsequent savings of hundreds of millions of dollars. The release also announced the creation of a new EPA office, the Office of Applied Science and Environmental Solutions (OASES), with a mission to “prioritize research and science more than ever before and put it at the forefront of rulemakings and technical assistance to states,” but provided no further information on the new office. 

To Administration supporters, this is the latest chapter in the long overdue reorganization of federal programs to help reduce costs and trim back the “administrative state.” To detractors, it is yet another broad attack on regulatory programs in general, especially those at EPA, and specifically targets the scientific work of EPA and its research office. ORD personnel reorganization was among the many ORD-specific recommendations outlined in the Project 2025 document. Critics of the Administration’s efforts to cut EPA’s budget and staffing see the reorganization of ORD and its associated staff cuts as part of the larger attempt to reduce protections of the environment and health at EPA and other government agencies — as part of the agenda to “gut” EPA programs generally, even if some program offices (including OCSPP) gain positions. 

ORD’s work, especially its Integrated Risk Information System (IRIS), has been controversial for many years and the subject of intense industry and trade group criticism. Established in 1985 and revised periodically, the IRIS Program is an attempt at a uniform, agency-wide database of human health assessments for chemicals found in the environment that serves as the basis for regulatory actions across EPA. The goal is that each EPA program be consistent in its assessments and able to act according to the specific legislative requirements driving the work of the respective EPA offices. The IRIS Program has evolved over time; its database was made publicly available in 1988 and there are now opportunities for public input into the IRIS process. At its best, the IRIS Program is hailed by supporters as being an essential part of bridge-building between different forms of environmental science and the various offices of EPA.

IRIS critics, however, have claimed for years that the program is overly conservative in its assessment assumptions, biased in its selection of information evaluated, and secretive in avoiding public scrutiny of its underlying work and assumptions. A January 27, 2025, letter organized by the American Chemistry Council (ACC) and signed by over 80 organizations affected by the work of the IRIS Program asserts:

IRIS has often fallen short of scientific standards required of EPA and is out of step with global health agencies and regulators. IRIS fails to adequately incorporate high quality and relevant science and does not consistently utilize a “weight of the scientific evidence” approach. Also, the process IRIS uses to prioritize and select chemicals for assessment lacks transparency.

For years, ORD has been subject to legislation introduced in Congress in response to the assertion of critics, most recently the “No IRIS” Act introduced in the House and Senate in February 2025 (H.R. 1415 and S. 623, respectively). The IRIS Program has been reviewed by the General Accountability Office (GAO) at various times over the years and found to indeed have program deficiencies (e.g., timeliness, lack of guidance) cited by critics as evidence of its ineffectiveness. EPA has implemented actions to satisfy the recommendations made by GAO, but some stakeholders remain very critical.

Critique of the IRIS Program is just one facet — there has been a long-standing assault on ORD’s assessment policies and assumptions used in ORD evaluations. In February 2025, partly in response to this sustained assault, EPA employees and supporters created Stand Up for Science. This grassroots movement turned non-profit organization has hosted rallies, created policy goals, and garnered media attention. Of note, the Stand Up for Science website hosts the public Declaration of Dissent, signed by EPA staff and members of the public, and invites visitors to add their name to the Declaration. The Declaration itself is addressed to EPA Administrator Lee Zeldin and highlights five main concerns. Concern number four is “Dismantling the Office of Research and Development.” The Declaration states that the proposed ORD reorganization will make “EPA science more vulnerable to political interference,” and cites the proposed budget cuts for 2026 as leaving “ORD unable to meet the science needs of the EPA and its partners” and in a place that “will threaten the health of all Americans.”

What any reorganization of ORD or reform of science activities and policies will have to confront is the requirement for a scientific basis at the heart of any regulatory decision. Regardless of presidential priorities or allocated budgets, much of EPA’s work will remain dependent on the underlying science supporting whatever regulatory conclusions are proposed. Those programmatic conclusions will then be subject to public review and comment as part of the fundamental regulatory development process. In the end, even if ORD, as a separate program office, is taken off the EPA organization chart, the need to coordinate science policies and review procedures across EPA programs will remain. The development of the IRIS Program was a response to the need for agency-wide procedures to avoid conflicting science among internal EPA programs. A chemical’s production, exposure, and environmental release might cut across many EPA programs, subject to a variety of environmental laws. That centralized science function was developed over time to reduce, and ideally eliminate, inconsistent science and avoid overlapping, unsupported, or inadequate requirements.

After the reorganization and budget allocations are settled, it is not clear what procedures or administrators will fill those needed functions of integration, coordination, and consistency. Debates, especially high-profile controversies, are often more about the derivative outcomes of an assessment masking as debates than about the underlying data and evaluation procedures. Reorganizing the pieces on the chess board will not resolve or avoid such debates in the future.