December 15, 2003

Public Interest Comment on Proposed Bulletin and Guidelines for Peer Review and Information Quality

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Whether they involve human medicines, endangered species, air and water quality, industrial chemicals, transportation safety, or consumer products, the stakes involved in federal regulatory decisions are enormous. OMB's periodic reports on the benefits and costs of federal regulation show that hundreds of billions of dollars turn on these decisions, but it is also true that lives are at stake, on both sides of the equation. It is important to get these decisions right, within the limits of human knowledge and analytical and policy development processes.

The proposed guidelines on peer review and information quality are an important advance, and we applaud OMB and OSTP for undertaking this effort. Peer review is an established process for quality control in the scientific community. While it is most closely associated with the publication of journal articles and the awarding of grants, the peer review process can and should be applied to the use of science in public policy.

We recognize that peer review is not perfect, as evidenced by well-documented examples of flawed science passing one level of peer review. Yet peer review "combined with independent replication" is the best way to achieve the highest standards of quality. The scientific peer review process needs to be adapted to the particular requirements of the rulemaking process. The proposed guidelines will consume additional resources if they are properly applied, and therefore should include a "look-back" provision to allow for a review of their value produced after a few years.