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CRE
Comments to
Department of 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.
Click
to review CRE's comment letter to DOL on the Risk Analysis portion of
its Data Quality Guidelines
Click to submit a comment
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."
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to review CRE's additional supplemental comment letter to DOL
Click to submit a comment
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.
Click
to review CRE's comment letter to DOL
Click
to review CRE's Generic Comments attachment
Click
to review Legal Memorandum on proposed agency exemptions to the Data Quality
Act guidelines
Click to submit a comment
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.
Click to read CRE letter to DOL
Click to read CRE white paper
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