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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
David Skorton, University of Iowa

Text of comment:

October 29, 2001

Ms. Brooke Dickson
Office of Information and Regulatory Affairs
Office of Management and Budget
Washington, D.C. 20503
RE: Final Guidelines for Ensuring and Maximizing the Quality,
Objectivity, Utility, and Integrity of Information Disseminated by Federal
Agencies (66 Fed. Reg. 49718)

Dear Ms. Dickson:

I am writing on behalf of the University of Iowa to comment on the “capable
of being substantially reproduced” standard contained in §§V.3.B., V.9, and
V.10 of the final guidelines cited above. The University of Iowa is a
Carnegie Mellon Research I Institution whose research activities would be
directly and very negatively affected by the standard as it is now
published. We are very concerned that the existing “reproducible” standard
will result in duplication of academic research studies by agencies that
will be discouraged from publishing the information due to the resulting
extra time and expense of repeating the studies, many of which will have
already undergone external peer review.

We are gratified to see OMB’s recognition in the final guidelines that
external peer review can be considered “generally” objective and that OMB
has provided for the need to protect personal private information and
intellectual property. We are also pleased that OMB has clarified that
original or supporting data is not subject to the “reproducible”
standard. These measures provide needed protections for research data used
by federal agencies.

However, at the same time, the fact that externally peer-reviewed
information is considered to be only presumptively objective in the final
guidelines, without any guidance as to how an agency may determine
otherwise, is in our view still highly problematic. This view of external
peer review seems to be based on the perception that peer review is
performed “in the back room,” a view that is inconsistent with that held by
those who actually devote much of their professional time to performing
peer review activities.

Additionally, although OMB specifies that only “influential”
scientific/statistical information is subject to the “reproducible”
standard, the definition of “influential” is so broad that it could
conceivably include much more than information that has an effect on
government policy or regulation; it would in fact appear to apply to any
agency-published information, without regard to its ultimate use or
effect. We would support limiting coverage to research results that are
used to support or develop federal regulations, as we understood to be the
intent of the original efforts that led to the guidelines that have now
been finalized.

We appreciate the opportunity to again address the issues presented by the
“substantially reproducible” standard and we thank you for your
consideration of our perspective on these issues.


David J. Skorton
Vice President for Research