Ethics for Advisory Committee Members
Generally, members of advisory committees and panels of the Science Advisory Board (SAB), Clean Air Scientific Advisory Committee (CASAC) and the Advisory Council on Clean Air Compliance Analysis (Council) are employed as Special Government Employees (SGEs) as defined under 18 U.S.C. 202(a). On occasion, Regular Government Employees (RGEs) serving in agencies other than EPA are also used as advisory committee panelists. SGEs assume the responsibilities, obligations, and restrictions that are part of public service. SGEs are required to abide by appropriate ethics regulations issued by the U.S. Office of Government Ethics. Among these requirements are the submission of a confidential financial disclosure form and completion of ethics training.
Confidential Financial Disclosure Form
SGEs are required to file a confidential financial disclosure report when first appointed to participate in an advisory activity, and then annually thereafter. SGEs must complete a "Confidential Financial Disclosure Form for Special Government Employees Serving on Federal Advisory Activities at the U.S. Environmental Protection Agency," EPA Form 3110-48 (PDF, 10 pp., 347 kb, About PDF Files). This form is used by Government officials to determine whether there are ethics issues with regard to the service of an SGE on an advisory committee or panel. Members of advisory committees or panels may also be required to update the confidential form before each meeting while they serve as SGEs. RGEs are required to submit either an OGE Form 450 (Confidential Financial Disclosure Report) or an SF-278 form (Public Financial Disclosure Report) as appropriate under regulations promulgated by the Office of Government Ethics.
SGEs are also required by regulation (5 C.F.R. Part 2638) to take ethics training before participating in an advisory activity and annually thereafter. RGEs take ethics training at their agencies as required by regulation (5 C.F.R. Part 2638). SGE ethics training is available as an on-line course available through the U.S. Office of Government Ethics (OGE). The on-line OGE “Ethics Training for Special Government Employees”
takes approximately one hour to complete.