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CRE Analysis

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

Comment by National Science Foundation

CRE Response:

Generally speaking, independent analysts wishing to confirm the conclusions of a federally sponsored study are unlikely to request lab notebooks, tissue cultures, and so forth. Rather, only the minimum amount of data necessary to reproduce the experiment or verify the analysis will be sought. There may be occasions, however, where recourse to the original numbers is necessary to replicate the findings of the original researcher. The scope of "data" needed for a sufficient review in these cases will likely have to be determined on a case by case basis.

In its April 5, 1999 comments, CRE offered the following definition of "data" to assist OMB in constructing a framework for the awarding agencies:

All tangible information or material, including but not limited to measurements, surveys, and experimental details, and subsequent data treatments, including statistical analyses, obtained, performed and compiled by researchers under an award.

In its August 11, 1999 reproposal OMB included the following definition of "data" for which it sought comment:

the recorded factual material commonly accepted in the scientific community as necessary to validate researching findings, but not any of the following: preliminary analyses, drafts of scientific papers, plans for future research, peer reviews, or communications with colleagues. This "recorded" material excludes physical objects (e.g., laboratory samples).

OMB further restricted the definition to exclude certain materials relating to intellectual property and personal/medical information.