DR. R. R. COLWELL

5010 RIVER HILL ROAD
BETHESDA, MARYLAND 20816
TEL. (301) 229-5129
CONSULTANT
MICROBIOLOGY & ENVIRONMENTAL SCIENCE

June 23, 2015
Al Horvath
Acting Secretary
Smithsonian Institution
MRC 016
PO Box 37012
Washington, DC 20013-7012
W. John Kress
Interim Under Secretary for Science
Smithsonian Institution
MRC 009,
PO Box 37012
Washington, DC 20013-7012

Dear Mr. Horvath and Dr. Kress,
At the Smithsonian Institution’s request, dated February 26, 2015, I agreed, as an external and
long-standing member of the scientific and research community to review the Smithsonian’s
guidelines and policies regarding the ethical conduct of its scientists and researchers with a
specific focus on stated conflicts of interests in connection with publications.
The review itself involved, and the resulting findings relied upon, my review of applicable
Smithsonian policies; policies from a variety of institutions designated as “peers” to the
Smithsonian; my own experience as environmental microbiologist and molecular biologist,
science administrator, and author or co-author of approximately 750 scientific, peer-reviewed
publications; and relevant information learned during meetings with a team of Smithsonian
staff who were similarly charged with evaluating the Smithsonian’s policies on conflict of
interest, research integrity, and publication disclosure requirements. I confirm these findings as
follows.
General Finding: The Smithsonian’s policies related to conflicts of interest and the disclosure of
the source of funds underlying published materials are generally consistent with industry best
continued practices. However, I recommend the Institution strengthen its existing policies and
modernize its operating procedures.

 Specific Findings:
1. In addition to existing annual disclosure mechanisms, the Smithsonian should review all
sponsored awards at the time of proposal for personal conflicts of interests.
2. The Smithsonian should formally adopt a set of baseline terms and conditions in
sponsored awards related to freedom to publish, confidentiality, and intellectual property
rights that are consistent with the Institution’s public mission and goal to disseminate
knowledge.
3. The Smithsonian should modernize and automate its annual financial disclosure
program in order to equip the Institution with the capacity to include all PIs in the
disclosure process irrespective of whether they are currently identified as mandatory
filers under existing Smithsonian policy.
4. The Smithsonian should adopt a publication disclosure policy more robust than the
industry standard and should require that Smithsonian staff disclose all sources of
research funding in connection with any publication written under a Staff member’s
Smithsonian affiliation irrespective of third party journal or publisher requirements, and
irrespective of whether the staff member deems his or her sponsored research related to
the findings set forth in a particular publication.
I trust these findings and recommendations will prove useful to the Smithsonian Institution. I
would like to express my appreciation for the superb assistance and cooperation provided by
the Smithsonian staff.
It is important to point out that I did not receive any compensation from the Smithsonian for this
effort. The Smithsonian was extremely helpful in providing the policies and materials necessary
to conduct the review in response to my request.
It has been a pleasure to have the opportunity to serve the Smithsonian Institution in this very
important task.
I will be very pleased to provide additional information or comment, if you should so require.
With best wishes,

Yours sincerely,

Rita R. Colwell, Ph.D., D.Sc.
Distinguished University Professor
University of Maryland College Park
and
Johns Hopkins University
Bloomberg School of Public Health