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Reports Covered by the DQA A peer review report is certainly a third-party report in the sense that it originates outside the agency. (Quaere: Who is the second party?) The way the OMB guidelines were originally written, however, the references to third-party information covered studies or other publications authored by persons outside the agency and completely independent of the agency, but which the agency might rely on or agree with. Peer review panels do not conduct new research or publish information; they review an agency report and advise the agency on the validity or weight of other parties research or other publications and are to a large extent under the control of the agency because the agency convenes the panel and charges it, and then, under the peer review guidance, must respond to the panel's review of the agency's draft. The peer review panel must, like the agency, apply the IQA and its guidance in its review of the agency draft, which would include the agency's reliance on, or agreement with, third-party research and conclusions. Thus, the peer review panel, unlike other third parties, is supposed to assist the agency in vetting the body of literature for compliance with IQA standards. A peer review panel has to comply with the IQA standards in reviewing the agency draft product (and should likewise ensure that the agency complies), but I think it is confusing to refer to it as a third party. If anything, it is more like a fourth party - acting as an intermediary between third parties and the agency. Under the guidelines, a third-party publication is considered an agency dissemination only if the public would reasonably believe that the agency agrees with the study. The link is to a web page that simply lists the study as a study that Pettis has contributed to, and the web page that is a listing of individual Pettis accomplishments, not agency publications or research. I don't think a simple listing of the study by the agency would be considered to reasonably suggest agreement. Besides, as cited, the study was conducted by three other authors who were not affiliated with USDA and two of whom had non-USDA financing (see acknowledgements section at end). However, if the agency were to rely on or otherwise agree with the study, the study would have to meet IQA standards. Also, you will note below that technically, Pettis perhaps should include a disclaimer of agency position with the publication (although in this case it is not just his publication, but a publication by four different authors). Below is the Guideline explanation: |
