In the last two weeks, most agencies covered by the Paperwork Reduction Act published proposed guidelines to implement the Data Quality Act, which was passed as a rider to an appropriations bill. The agency guidelines are to comport with guidelines developed by the Office of Management and Budget (OMB) earlier this year. The list of agency guidelines is available online. Most agencies provide until the end of May to submit comments on the guidelines. The OMB guidelines require agencies to establish procedures for ensuring high quality of the information disseminated and used by agencies. OMB notes that as the importance of the information grows so too does the obligation to ensure quality with "influential" information requiring the highest standard. OMB argues that there are three types of "influential" information, each requiring levels of transparency so that the results can be reproducible. For analysis of risks, OMB urges agencies to adopt or adapt its preferred choice for doing risk assessments. Most agencies seem to have adapted the OMB procedures. OMB also requires agencies to have in place administrative mechanisms by October 1 to allow "affected persons" to seek and obtain timely correction of information disseminated by the agency. In its final action on the guidelines, OMB added a requirement that agencies are to establish an appeals process for those unhappy about agency actions on error correction. The guidelines leave it to agencies -- or perhaps the courts -- to determine how formal the appeals process must be and whether it is an adjudicatory one. It also leaves it to agencies to determine how long the public will have to raise corrections that are needed. Many in the public interest community are concerned that this administrative mechanism will be a tool for industry to slow down, if not stop, agency regulatory activities since regulations are based on research that will be subjected to the Data Quality Act. The Chamber of Commerce has argued that these Data Quality guidelines are the most important regulatory change since passage of the Administrative Procedure Act in the 1940s. OMB also instructs agencies to develop pre-dissemination quality reviews for information the agency disseminates after October 1. Agencies may utilize existing practices to meet this requirement. There are many other requirements agencies must determine, such as how they will use independent, external peer review. OMB urges such peer review, but indicates it, alone, may not be sufficient for determining data quality. OMB also adopts a peer review policy that does not require public disclosure of whether peer reviewers have any conflicts of interest. Most of the smaller agencies have provided a parroting of the OMB guidelines suggesting that it will still take time to know how these new rules will be implemented. One agency, EPA, notes at the onset that a core mission of the agency is dissemination of environmental information in order to strengthen environmental protections. It appears to be one of the few agencies that starts from that premise. OMB Watch will be preparing additional materials on the agency data quality guidelines. We will also be speaking at a public meeting EPA is providing on May 15.