When Ethics Are Ignored, Science Suffers and the Public Is Misinformed
Sound science demands rigorous application of ethical guidelines. Objective standards of good conduct ensure integrity and consistency, and give the public confidence in conclusions reached by careful research. Journals and other outlets that publish scientific findings thus have a responsibility to disclose any obvious and material conflicts of interest implicating research authors or organizations tone and intent.
In the case of a recent series of papers published by Christoph Koch, on Polymeric FR degradation as a function of Heat and UV exposure, the gatekeepers at Environmental Science & Technology (ES&T) and Environmental Health News (EHN) failed in this duty. So we brought it to the attention of their editors. The ethical guidelines for technical papers, as laid out in ACS Ethical Guidelines to Publication of Chemical Research and the guide for Author submissions in Chemosphere, are clear. And while the journals eventually took partial responsibility and updated the research to include additional disclosure, it was too late to prevent both technical and mainstream coverage from propagating flawed information to their audiences.
To be clear, no journal publishing Koch’s work should allow him to obfuscate his clear conflict of interest, nor downplay how it compromises his research. His association with the Deutsche Rockwool GmbH & Co. KG (“Rockwool”) organization was initially relegated to a footnote in ES&T. that is not a disclosure. This is a disqualifier. And we think the subject deserves a more thoughtful and thorough treatment. An addition was finally added to Koch’s paper clarifying his work for Rockwool in ES&T, but Koch still denies any conflict of interest.
Rockwool sells insulation products and competes directly in the marketplace with the polystyrene foam insulation producers who utilize the very same Polymeric FR technology Mr. Koch chose to research. Rockwool has an established record of seeking out publication material that would help the company gain a competitive advantage in the marketplace. For example, Rockwool sponsored a 2013 publication examining HBCDD, which has been proposed as an alternative flame retardant in competing polystyrene foam insulation products. Rather than support research on substances used in their own products, Rockwool focused instead on existing and new replacement flame retardants used by their competitors.
These competing interests cast Mr. Koch’s entire body of work in a very worrisome light—one that calls into question his methods and his conclusions. It is impossible to separate Koch’s connection to the Rockwool Company from his choice of a research topic. It aligns directly to Rockwool’s interest as a commercial entity and its business strategy. A published addition to Koch’s latest paper claims that Rockwool did not directly fund this particular Polymeric FR study. But that is irrelevant. Money is fungible, and Koch had a clear financial stake that motivated his unprofessional behavior.
Mr. Koch’s employment with Rockwool is not necessarily known to the general readership in this particular area of research. However it seems to extend back to at least 2015, according to his publication history. His recent papers, in ES&T and Chemosphere, include research timelines that show his work included a minimum of three and a half years as an employee of Rockwool, during which time he also published another paper, submitted in 2014 and published in 2015, which examined legislation around the continued use of HBCD, commonly used by the polystyrene insulation industry before Polymeric FR was commercially available. This particular paper’s author information shows Koch’s connection to “Deutsche Rockwool Mineralwoll GmbH & Co. OHG, 45966, Gladbeck, Germany.” Therefore on the heels of the Rockwool funded study in 2013 on HBCDD, four papers have been produced by Koch on flame retardants his company’s competitors use in the manufacture of their foam insulation products.
Together, these facts clearly establish a precedent and more importantly a “significant financial interest in corporate or commercial entities dealing with the subject of the manuscript.” This should have been acknowledged. And yet it was only after being pressed by our industry that Koch added a note to his paper published in ES&T:
“The authors wish to clarify that whereas the first author, Christoph Koch, is affiliated with Deutsche Rockwool GmbH & Co. KG, none of the funding for this project was provided by this company, nor has there been any other influence regarding this research project. The publication is part of his Ph.D. project, which he already started before he was affiliated with Deutsche Rockwool GmbH & Co. KG and which he continued in his free time. The study was solely supported by university funds. The Conflict of Interest statement and other funding sources are correct as published in this article.” [Emphasis ours]
This explanation is difficult to accept based on the established relationship between the author and Rockwool. In the space of five years, five different papers have been produced on the detrimental effects of flame retardants used, or soon to be used, by their competitors. Clearly Mr. Koch’s employer and the topic of flame retardants in competing polystyrene insulation was a long standing factor in his work.
Significantly, in his new July 2019 paper in Chemosphere8, Mr. Koch has committed an about face from the conclusions of previously published paper for ES&T in January of 2019, and now concludes Polymeric FR is safe for polystyrene foam insulation use after all. However the damage has been done: Mr. Koch has succeeded in stoking confusion and controversy over a new technology his employer competes with in the marketplace.
A clearer disclosure of a longstanding relationship between Mr. Koch and Rockwool would have invited greater scrutiny, both by the journals reviewing these manuscripts for publication, and the media outlets who subsequently reported on the published work. At the very least, it might have compelled those publications to reach out to the maker of Polymeric FR for technical responses.
The American Chemical Society and Chemosphere created policies of disclosure to avoid these very kinds of problems, and yet in this case they have been violated throughout both in letter and in spirit. Accurate disclosure is the only way to ensure the transparency necessary to resolve this problem, it is unfortunate in this occurrence that it came only after we openly questioned the research findings and connected the market advantage the author’s company would experience by publishing unfavorable results.
In the meantime, we are glad that sound science has borne out a vital conclusion that will save lives: Polymeric FR is safe.
 Koch, C.; Nachev, M.; Klein, J.; Koster, D.; Schmitz, O.J.; Schmidt, T.C.; Sures, B. Degradation of the Polymeric Brominated Flame Retardant “Polymeric FR” by Heat and UV Exposure,. Environ. Sci. Technol., 2019, 53 (3), pp 1453–1462.
 Ethical Guidelines to Publication of Chemical Research, Environ. Sci. Technol. 2015. https://pubs.acs.org/userimages/ContentEditor/1218054468605/ethics.pdf (accessed January 12, 2019).
 Sicherheitsdatenblatt, RockTect Multikit, Deutsche Rockwool GmbH & Co. KG, revised December 12, 2018. https://cdn01.rockwool.de/siteassets/rw-d/sicherheitsdatenblatter-sdb/hochbau-und-flachdach/sdb-rocktect-multikit-de-rockwool.pdf?f=20181212031247 (accessed January 13, 2018).
 Koch, C., Nachev, M., Klein, J., Koster, D., Schmitz, O. J., Schmidt, T. C., Sures, B. Addition to “Degradation of the Polymeric Brominated Flame Retardant ‘Polymeric FR’ by Heat and UV Exposure”. Environ. Sci. Technol. DOI: 10.1021/acs.est.9b01145.
 Christoph Koch, Bernd Sures “Degradation of brominated polymeric flame retardants and effects of generated decomposition products”. Chemosphere (2019), doi:10.1016/j.chemosphere.2019.04.052
 Koch, C., Schmidt-Koetters, T., Rupp, R., Sures, B. Review of hexabromocyclododecane (HBCD) with a focus on legislation and recent publications concerning toxicokinetics and dynamics. Environmental Pollution, 199 (2015) 26-34
 Koch, C.; Sures, B. Ecotoxicological Characterization of Possible Degradation Products of the Polymeric Flame Retardant “Polymeric FR” Using Algae and Daphnia OECD Tests. Science of the Total Environment. 2019, 656, pp 101-107.