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Public Comment Regarding: Additional comments on OMB Guidance on "Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies," on paragraphs V.3.B, V.9, and V.10, on the "capable of being substantially reproducible" standard.

Date: 10/29/2001

Signer Organization
Howard K. Schachman, American Society for Biochemistry and Molecular Biology

Text of comment:

October 29, 2001

Ms. Brooke Dickson
Office of Information and Regulatory Affairs
Office of Management and Budget
Washington DC 20503

Dear Ms. Dickson:

I am writing as chairman of the Regulatory Burden Subcommittee of the
American Society for Biochemistry and Molecular Biology's Public Affairs
Advisory Committee. I wish to comment on the final Guidelines for Ensuring
and Maximizing the Quality, Objectivity, Utility, and Integrity of
Information Dissemination by Federal Agencies. These guidelines were
published on September 28, 2001, with certain sections still open for
comment through today.

Thank you for your efforts to be responsive to many of our concerns about
the draft version of this notice, which we wrote to you about on August 13,
2001. However, we continue to have concerns about the "substantial
reproducibility" language in the final version.

Our objections to this language boil down to the concern that the
"substantial reproducibility" standard in the guidelines is inherently
subjective, and will likely create more difficulty for agencies rather than
less. We strongly endorse the comments on this matter expressed by the
Council of Government Relations (COGR) in its letter of October 26. COGR's
proposed solution to the problem is an excellent one?that "the
administration should direct agencies to rely on peer review for all
information in the scientific and research context, proposed for
dissemination by the agencies." This allows peer review?the ultimate
arbiter of truth and objectivity in scientific literature?to serve as an
effective barrier to the sort of problems and that could result from agency
reliance on a less adequate measure of objectivity.

Thank you for the opportunity to comment once again on these important


Howard K. Schachman