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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
Lydia Villa-Komaroff, Northwestern University

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: Comments on Interim Final Standard - Guidelines for Ensuring and
Maximizing the Quality, Objectivity, Utility and Integrity of Information
Disseminated by Federal Agencies (V.3.B, V.9 and V.10)

Dear Ms. Dickson:

Thank you for the opportunity to provide comments on the referenced Interim
Final Standard, issued on September 28, 2001. We are pleased with the
changes that have been made, based on comments received in response to the
June 28th, 2001 issuance. However, we continue to have a number of
concerns about these guidelines.

Although OIRA recognizes the importance of the peer review process and the
standard for determining objectivity in research, which we view as very
positive, it has limited the acceptability of peer review by federal
agencies. OIRA continues to maintain that the "substantial reproducibility
standard" be added to the peer review standards "in those situations
involving influential scientific or statistical information." We believe
that the peer review process is robust and should be relied on without the
introduction of additional review criterion

We agree with the three concerns articulated by the Council on Governmental
Relations: the objectivity standard, the definition of "objectivity" in
subjective terms, and the applicability of the criterion only to
"influential" scientific and statistical information.

Rather than introducing yet another set of requirements for independent
analysis, we strongly recommend that agencies rely on the peer review
process as the established mechanism for determining the objectivity of
scientific information. Following a designated period of time, if it is
determined that peer review is not adequate in all cases, additional
criterion could be introduced. This model mirrors demonstrations
undertaken by the Federal Demonstration Partnership (FDP). As an
Institutional Member of the FDP, which is committed to streamlining
administrative processes without negatively impacting stewardship
responsibilities, we support this demonstration strategy.

Thank you for the opportunity to provide comments.

Lydia Villa-Komaroff

Lydia Villa-Komaroff, Ph.D.
Vice President for Research
Northwestern University
633 Clark Street
Evanston, IL 60208
Administrative Secretary: Faith Hundahl
847-491-3485 fax 847-467-4620