Department of Agriculture

CRE Submits Additional Supplemental Comments to USDA on its Data Quality Guidelines
CRE has provided further supplemental written comments to USDA on its proposed Data Quality guidelines. These comments raise additional points on handling correction requests and also discuss the definition of the term "utility."

Department of Energy

CRE Submits Comments to DOE on its Proposed Data Quality Guidelines
CRE has provided written comments to the Department of Energy (DOE) on its proposed Data Quality guidelines. CRE's comments commend DOE for specifically adapting the Safe Drinking Water Act (SDWA) risk assessment standards for environmental risk assessments. However, the Center also recommended several changes in DOE's proposed guidelines, for example urging application of the Data Quality guidelines' petition process to rulemakings.

In addition to its letter comments, the Center has attached two papers: (1) a set of CRE Generic Comments to all agencies on their Data Quality guidelines which discuss a variety of important cross-cutting issues; and (2) a Legal Memorandum challenging the OMB's and other agencies' attempts to exempt certain categories of information from the Data Quality Act guidelines' applicability.

Environmental Protection Agency

Data Quality Act: CRE Submits Supplemental Comments to EPA on its Data Quality Guidelines
CRE has provided supplemental written comments to EPA on its proposed Data Quality guidelines. In addition to its supplemental cover letter, the Center has attached comments submitted to EPA by the Department of the Air Force on the perchlorate risk assessment. This attachment is provided because it is relevant and applicable to the Data Quality issues raised by EPA's current ban on third party clinical humn test data.

CRE Submits Additional Supplemental Comments to EPA on its Data Quality Guidelines
CRE has provided further supplemental written comments to EPA on its proposed Data Quality guidelines. These comments raise additional points on handling correction requests and also discuss the definition of the term "utility."

Data Quality Act: CRE Submits Comments to EPA on its Data Quality Guidelines
CRE has provided specific written comments to EPA on its proposed Data Quality guidelines. In addition to its letter, the Center has attached four papers: (1) CRE comments specific to EPA's Data Quality guidelines; (2) a set of CRE Generic Comments to all agencies on their Data Quality guidelines which discuss a variety of important cross-cutting issues; (3) a Legal Memorandum challenging the OMB's and other agencies' attempts to exempt certain categories of information from the Data Quality Act guidelines' applicability; and (4) CRE's Human Testing Petition to EPA.

EPA Ban on Third Party Clinical Human Test Data Violates Data Quality Act
CRE has informed EPA that the agency's ban on third party clinical human test data, pending National Academy of Sciences (NAS) review, violates the Data Quality Act. In its letter to EPA, the Center points out that these data are among the best available information regarding any substance's risk to human health, and the Act requires the agency to consider and use the best available data on health risks. Therefore, EPA's categorical refusal to consider these data is a clear violation of the Act and OMB's implementing Data Quality guidelines. CRE urges EPA to change its position now. CRE is including this letter as part of its comments on EPA's proposed Data Quality guidelines.

CRE Submits Comments to EPA on the Agency's Data Quality Guidelines
EPA, in a precedent-setting move, has requested public comments prior to proposing the agency's conforming Data Quality guidelines. CRE applauds this step designed to promote early public involvement and input, and urges other agencies to adopt this approach. CRE has taken this opportunity to address a number of issues which should be considered by other federal agencies in drafting Data Quality guidelines. CRE is making its comments available immediately so as to be useful in the context of the Data Quality Workshop being hosted by the National Academy of Sciences on March 21-22. CRE encourages all interested parties to submit their input on CRE's comments.

CRE Seeks Public Disclosure of EPA's Multi-Pollutant Air Emission Model
EPA is using an ICF Model to predict the economic effects of multi-pollutant air emission legislation being considered by Congress and the Administration. These modeling results could have a major impact on both the legislation and the economy. Their accuracy and reproducibility are critically important. Yet EPA has not allowed public review of and comment on the Model. Given the importance of this issue, CRE has sent EPA's Chief Information Officer a letter urging her to disclose the Model to the public. CRE has also filed a Freedom of Information Act request for the Model and related documents.

CRE Data Quality Petition to EPA on Global Climate Change
CRE is concerned that EPA disseminates public documents (such as Federal Register notices and Internet Website pages) that lead readers to believe that we know as scientific fact that: (1) global climate change is occurring because of anthropogenic emissions of greenhouse gases; and (2) the effects will include numerous specific adverse effects on human health and the environment. CRE petitioned EPA to correct a recent Federal Register notice, by publishing a notice alerting readers about the considerable scientific uncertainties surrounding the issue of global climate change. CRE also petitioned EPA to assure that all future EPA public documents that describe potential global climate change include a statement about scientific uncertainties.

CRE Petitions EPA to Modify EPA's Global Warming Website to Correct the Misleading and Incorrect Presentation of Information to the Public

FTC

Data Quality Act: CRE Submits Comments to FTC on its Data Quality Guidelines
CRE has provided specific written comments to the Federal Trade Commission (FTC) on its proposed Data Quality guidelines. In addition to its letter comments, the Center has attached two papers: (1) a set of CRE Generic Comments to all agencies on their Data Quality guidelines which discuss a variety of important cross-cutting issues; and (2) a Legal Memorandum challenging the OMB's and other agencies= attempts to exempt certain categories of information from the Data Quality Act guidelines' applicability.

HHS

CRE Submits Additional Supplemental Comments to HHS on its Data Quality Guidelines
CRE has provided further supplemental written comments to HHS on its proposed Data Quality guidelines. These comments raise additional points on handling correction requests and also discuss the definition of the term "utility."

Data Quality Act: CRE Submits Comments to CDC/ATSDR on its Data Quality Guidelines
CRE has provided specific written comments to CDC on its proposed Data Quality guidelines. In addition to its letter comments, the Center has attached two papers: (1) a set of CRE Generic Comments to all agencies on their Data Quality guidelines which discuss a variety of important cross-cutting issues; and (2) a Legal Memorandum challenging the OMB's and other agencies' attempts to exempt certain categories of information from the Data Quality Act guidelines' applicability.

Data Quality Act: CRE Submits Comments to FDA on its Data Quality Guidelines
CRE has provided specific written comments to the Food and Drug Administration (FDA) on its proposed Data Quality guidelines. In addition to its letter comments, the Center has attached three papers: (1) a set of CRE Generic Comments to all agencies on their Data Quality guidelines which discuss a variety of important cross-cutting issues; (2) a Legal Memorandum challenging the OMB's and other agencies= attempts to exempt certain categories of information from the Data Quality Act guidelines' applicability; and (3) CRE's earlier letter to FDA recommending applicability of the Data Quality guidelines to the activities of the interagency Risk Assessment Consortium which deals with food safety risks.

Data Quality Act: CRE Requests HHS/FDA Data Quality Guidelines Address Reduced Risk Initiatives
CRE has written HHS to request that, in view of the FDA's responsibilities as Chair of the federal interagency Risk Assessment Consortium (RAC), the Department should ensure uniform, government-wide Data Quality standards for evaluating risk reduction initiatives.

Labor

CRE Submits Comments to DOL on the Risk Analysis Portion of its Data Quality Guidelines (Applicable to OSHA/MSHA)
CRE has provided written comments to DOL on the Risk Analysis portion of its proposed Data Quality guidelines relating to OSHA/MSHA. The Risk Analysis section was released separately by the agency, after issuance of the rest of the DOL guidelines. CRE's comments raise serious concerns regarding DOL's "adaptation" of the SDWA guidelines. Specifically, DOL's proposed guidelines would not set minimum quality standards for risk-related information.

CRE Submits Additional Supplemental Comments to DOL on its Data Quality Guidelines
CRE has provided further supplemental written comments to DOL on its proposed Data Quality guidelines. These comments raise additional points on handling correction requests and also discuss the definition of the term "utility."

Data Quality Act: CRE Submits Comments to Department of Labor on its Data Quality Guidelines
CRE has provided specific written comments to the Department of Labor (DOL) on its proposed Data Quality guidelines. In addition to its letter comments, the Center has attached two papers: (1) a set of CRE Generic Comments to all agencies on their Data Quality guidelines which discuss a variety of important cross-cutting issues; and (2) a Legal Memorandum challenging the OMB's and other agencies' attempts to exempt certain categories of information from the Data Quality Act guidelines' applicability.

Federal Data Quality Act: CRE Files Data Quality Guideline Development Guide with DOL
CRE has provided the Department of Labor with a Working Draft white paper, Developing DOL's Data Quality Guidelines: A Step-by-Step Guide, designed to assist DOL in developing their Data Quality guidelines. A key issue discussed in the CRE guide is a discussion of the Department's duty to establish a standard for information reproducibility. CRE recommended that DOL's reproducibility standard include specific tests of robustness for all information subject to the reproducibility requirement to ensure that any and all test results are reliable.

OMB

CRE Submits Comments to OMB on its Data Quality Guidelines
CRE has submitted comments to OMB on its OMB-specific proposed Data Quality guidelines. In addition to its letter comments, the Center has attached four papers: (1) a set of CRE Generic Comments to all agencies on their Data Quality guidelines which discuss a variety of important cross-cutting issues; and (2) a Legal Memorandum challenging OMB's and other agencies' attempts to exempt certain categories of information from the Data Quality Act guidelines' applicability; (3) Comment on EPA's proposed Data Quality guidelines submitted by the ABA Section on Administrative Law and Regulatory Practice, and (4) supplemental comments specifically related to risk issues.

CRE Submits Comments on "Reproducibility" Standard in OMB's Data Quality Guidelines
CRE submitted comments to OMB on the "capable of being substantially reproduced" standard included in the agency's final Data Quality guidelines. The reproducibility standard was issued on an interim final basis, and OMB accepted additional public comments on that key aspect of the guidelines through October 29, 2001. CRE strongly supports OMB's reproducibility requirement as a standard of care for governmental information. If information is not sufficiently robust that it cannot be reproduced by independent parties across testing environments, it should not be deemed adequately reliable for dissemination to the public. CRE urges OMB to retain this important aspect of the guidelines.

Office of Science and Technology Policy (OSTP)

CRE Submits Additional Supplemental Comments to OSTP on its Data Quality Guidelines
CRE has provided further supplemental written comments to OSTP on its proposed Data Quality guidelines. These comments raise additional points on handling correction requests and also discuss the definition of the term "utility."

Data Quality Act: CRE Submits Comments to Office of Science and Technology Policy on its Data Quality Guidelines
The Office of Science and Technology Policy's (OSTP) proposed Data Quality guidelines impose statutes of limitation for filing administrative correction petitions. Petitions that are not filed within very short periods of time after the information is disseminated could never be filed at all. These deadlines for filing petitions are so short that they would in effect deny the right to file a Data Quality petition to anyone who does not follow OSTP on a daily basis. CRE does not believe that Congress intended to restrict Data Quality petitions in this manner. CRE's comments urge OSTP not to impose these statutes of limitation for filing petitions. In addition, CRE's comments ask OSTP to address the issue of how the Data Quality guidelines apply when interagency committees, comprised of several federal agencies, disseminate information. OSTP is an appropriate agency to address this issue because it is involved in several of these interagency committees. CRE's comments propose an approach to this issue.

Data Quality Act: CRE Submits Comments to Office of Science and Technology Policy on its Data Quality Guidelines
CRE has provided written comments to the agency on its proposed Data Quality guidelines. In addition to its letter comments, the Center has attached two papers: (1) a set of CRE Generic Comments to all agencies on their Data Quality guidelines which discuss a variety of important cross-cutting issues; and (2) a Legal Memorandum challenging the OMB's and other agencies' attempts to exempt certain categories of information from the Data Quality Act guidelines' applicability.

CRE Requests Withdrawal Of The National Assessment On Climate Change On Federal Data Quality Act (FDQA) Grounds
CRE has requested that the United States Global Change Research Program and the Office of Science and Technology withdraw the First National Assessment on Global Climate Change because it violates the objectivity, utility and reproducibility requirements of the Data Quality Act and OMB's guidelines implementing the Act. More specifically, the National Assessment violates the Act and OMB's guidelines.

SEC

CRE Proposes Alternative to Additional Regulation of the Securities Market
Over-regulation of Corporate America will reduce innovation and suppress economic growth. As is usual when there is a failure in the markets, the government's first instinct is to respond with additional regulatory proposals, without first studying ways to strengthen the existing regulatory system. It is this habitual discarding of existing systems and the creation of new ones that contributes to an increase in the federal regulatory reach. A case in point is the current failures in the securities markets. Congress is considering passage of laws to expand regulation of corporations and to create a vast new regulatory bureaucracy to check financial reports. However, before such steps are taken, CRE recommends consideration of the alternative of applying Data Quality Act guidelines to the corporate data submitted to the SEC. CRE has under consideration a proposal to develop Data Quality standards specific to financial reports; CRE welcomes your views on developing this proposal. In particular, applying the Data Quality Act to corporate filings at the SEC is an alternative to creation of the Accounting Oversight Board contained in the Senate bill.