What Does a Much Smaller Office of Research and Development Mean?
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 plan’s stated goal is to reduce budget expenditures, improve science, and have EPA’s research activities better support the work of EPA’s media offices.
The EPA press release refers to the reorganization 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.
So what does a much smaller ORD mean?
Background
EPA’s July 18 announcement was among the many ORD-specific recommendations outlined in the Project 2025 document, so EPA’s recent announcement was not entirely surprising. The reorganization is believed to affect between 900 and 1,000 employees.
Critics of the administration claim ORD’s reorganization reduces protections of the environment and human health at EPA and other government agencies. Supporters see the reorganization as a long-overdue effort to streamline research efforts, align them with agency priorities and curb ORD’s overly conservative tendencies when assessing risks.
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. The IRIS Program seeks to maintain a uniform, agency-wide database of human health assessments for chemicals found in the environment to serve as the basis for EPA regulatory actions.
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 program 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.
Impact on Chemicals
Certain functions ORD was supporting are uniquely impactful for the chemical community. ORD was, for example, a leader in the New Approach Methods (NAM) area, identifying alternatives to the use of animals in the testing of chemicals. EPA may continue this work by outsourcing it, as NAMs hold considerable promise in accelerating health hazard assessment, but this is unclear.
Similarly, ORD’s Chemical Safety for Sustainability research program was helping to identify the safe production, use and disposal of chemicals to support improved decision-making on chemicals. EPA’s Toxic Substances Control Act (TSCA) new chemicals program may have relied on these efforts to support its review of new chemicals under TSCA Section 5. After the reorganization and budget allocations are settled, it is not clear what procedures, EPA offices or outsourced vendors will fill those functions and many others supporting the chemical community and many other industry sectors in a variety of targeted research areas.
On the good news side, EPA’s Office of Chemical Safety and Pollution Prevention (OCSPP) announced earlier this summer that it is set to absorb approximately 130 ORD professionals. It is hoped that the consolidation of these professionals with OCSPP will enhance operational efficiency and support more robustly EPA’s chemicals and pesticides programs.
Broader Considerations
What any reorganization of ORD must confront is the foundational requirement for a scientific basis at the heart of EPA’s regulatory decisions. Regardless of EPA 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 be subject to public review and comment as part of the administrative process.
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 IRIS Program was a response to the need for agency-wide procedures to avoid conflicting science among internal EPA programs. That centralized science function was developed over time to reduce, and ideally eliminate, inconsistent science and to avoid overlapping, unsupported or inadequate requirements. Some speculate the new OASES will serve this need. The answer to this question, and more broadly, how the newly recognized EPA writ large will achieve this goal, is anxiously awaited by all.
Lynn L. Bergeson, Compliance Advisor columnist
LYNN L. BERGESON is managing director of Bergeson & Campbell, P.C., a Washington, D.C.-based law firm that concentrates on conventional, biobased, and nanoscale chemical industry issues. She served as chair of the American Bar Association Section of Environment, Energy, and Resources (2005-2006). The views expressed herein are solely those of the author. This column is not intended to provide, nor should be construed as, legal advice.
