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Interactive Public Docket

Data Access

CRE Analysis

12. The proposed OMB revision does not define the term "data."

Background:

OMB's February 4, 1999 proposed revision did not define the term "data", and the absence of a definition, perhaps more than any other single issue, prompted a wide range of comment from all sides of the data access debate. Researchers generally were concerned that an overly broad definition could lead to unwarranted and invasive disclosures of lab samples, field notebooks, cell cultures, and even "Post-It" notes. Arguments also were raised that too a broad definition could take in confidential materials including video tape interviews of research subjects. Supporters of data access recognized the need for some limitation of the kinds of material that researcher would be required to disclose, but they argued that the definition should not be so limited as to impede the ability of an independent researcher to replicate the first researcher's findings.