June 27, 2002

Public Interest Comment on the U.S. Consumer Product Safety Commission Draft Information Quality Guidelines

Key materials
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Stated Purpose:

Guidelines describe how the CPSC intends to ensure that the information it disseminates exhibits utility, objectivity, and integrity.

Summary of RSP Comment:

High quality data and information are crucial for informed policy decisions. To that end, OMB directed agencies to develop data quality guidelines meant to ensure consistently high quality in the information disseminated by federal agencies. The CPSC's data quality guidelines provide few specifics regarding what procedures the Commission intends to follow, instead relying on the technical expertise of its staff to ensure the use and dissemination of high quality information. The guidelines do little to instill confidence in CPSC's information products.

In many ways, the CPSC's data quality guidelines read more like an outline or proposal than actual guidelines themselves. Effectively, in its attempt to lay out guidelines general enough to govern all instances of data dissemination, the CPSC does little to explain exactly how it will warrant the quality of data in any given situation. While generalized principles are important to the extent that they replace completely ad hoc data quality control procedures, the guidelines presented by the CPSC are so vague that the guidelines might just as well not exist. This comment presents suggestions regarding how to draft guidelines that are general without being vacuous by committing to specific warranties or disclaimers for all information disseminated by the CPSC. Specifically, the Commission needs to

  • Explain its quality control procedure in greater detail;
  • Adopt a uniform system of warranties and disclaimers certifying that all information has been subjected to the quality control procedures;
  • Commit to justifying the use of any given dataset instead of the available alternatives through cost benefit analysis.