OMB Bulletin on Peer Review: Making Science Vulnerable to Political Manipulation Download response (.pdf) The Office of Information and Regulatory Affairs (OIRA) within the Office of Management and Budget (OMB) today released a draft bulletin proposing peer review requirements for all agencies. OMB seeks public comment on the bulletin and its proposals until October 28 with the intention that final bulletin will take effect next February. This well-meaning effort to give academics and scientific experts more influence in policy development may actually result in giving politics greater influence over science. Peer review is the process by which experts in the field review and critique studies and papers in an effort to assure the quality of the research. Since peer review is typically a positive and beneficial process, OMB's desire to increase and improve its use in agencies is not unreasonable. However, in trying to accomplish that goal it seems OMB is creating an overly restrictive and centralized process that will be dangerously vulnerable to political manipulation. Restrictive Many agencies, as acknowledged in the bulletin, have active peer review programs developed to fit their needs. Currently agencies have flexibility in the implementation of their peer review programs depending on the type of information, reviewer availability, and speed of planned action. The bulletin would require that agencies peer review all "significant regulatory information" while exempting certain types of information such as grants and routine statistical information. This could strip agencies of the ability to respond quickly to an emerging issue such as a newly identified threat to health or safety. The bulletin does propose allowing agency administrators to waive some or all of the peer review requirements in cases of imminent health hazards, homeland security threats and other emergencies. However, the administrator must consult with the Office of Science and Technology Policy (OSTP) before granting the waiver. Even with the waiver these requirement the guidance could provide the legal basis for industry to delay or even block agencies' emergency activities and other regulatory actions in court if certain aspects of the peer review process have not been completed. Under the current system these decisions and timing are entirely at the agencies' discretion. Vulnerable to Manipulation The bulletin contains several troubling references that may increase political influence and potentially centralize the peer reviewing process. One provision in the bulletin would require agencies to obtain input and approval of their peer review policies from OIRA and OSTP. This grants two White House offices enormous influence over the peer review policies and subsequent processes. The bulletin increases this influence with the requirement that agencies, when requested to do so, consult with OIRA on plans to review specific documents. The bulletin notes that this consultation will qualify as one of the pre-dissemination quality procedures required under the Data Quality Guidelines. An even more disconcerting section of the bulletin requests comments on whether agencies should retain the ability to select their own peer reviewers. OMB remarks that a centralized body in charge of appointing reviewers and overseeing peer reviews might be an improvement. However, a centralized organization managing peer review throughout the federal government would have an excessive amount of control over the process. A single peer review entity would also be extremely vulnerable to political manipulation that is more difficult to exert broadly in a decentralized system. The "outside entity" could also be an industry group; further increasing corporations' access and influence in policy development. Additionally, this section implies that there should be uniform processes for doing peer reviews, raising questions about the advisability of forcing uniformity across the government. While OMB notes that it is not proposing such as system in this bulletin, the request for comments indicates the office's interest in this approach and could well signal the direction of future guidance. These policies would enable the administration to easily rig the peer review process and guarantee a desired outcome from scientists. The Bush administration has already dismissed scientific evidence of global warming that counters its position on the issue and so heavily rewrote a global warming chapter in EPA's Report on the Environment the agency eliminated the chapter entirely. Would scientific review really be improved by granting such an administration more authority and influence? OMB Watch thinks not. No White House office, particularly one as highly political as OIRA, should have such influence over the "objective science" that policymakers use. Conclusion Just as the bulletin notes that this guidance supplements the Data Quality Guidelines, OMB Watch believes this proposal suffers from the same shortsightedness that produced those guidelines. OMB seems to develop policies for implementation in an ideal world free from of misuse and mismanagement. The reality is that our policies must be designed to resist such manipulations. A flexible and decentralized peer review system, while still susceptible to uneven implementation and some misuse would be the most resistant to extensive abuse. OMB Watch believes that a better approach would first analyze the various peer review programs in place and identify the best aspects to be duplicated. OMB should also have elicited more input from those involved in every aspect of the peer review process prior to drafting any guidance. Additionally, the guidance should have continued to strongly recommend these peer review policies rather than requiring them for all significant regulatory information. OMB notes in the bulletin that they are accepting comments on the proposal through October 28, 2003 and that it intends for the final guidance to go into effect for all information disseminated after January 1, 2004.