Data Quality Approaches

Government agencies are busy working on their data quality guidelines with many looking to a draft release for public comment in May. According to the Office of Management and Budget (OMB) guidelines, issued January 3, 2002, each agency must implement agency specific information quality guidelines by October 1, 2002. A great deal of concern surrounds the Data Quality guidelines since several business groups categorized these guidelines as the best opportunity to challenge regulatory protections since passage of the Administrative Procedure Act in the 1940's. One organization, The Center for Regulatory Effectiveness, didn’t even wait for the guidelines to be finalized before challenging, in a letter to the White House Office of Science and Technology Policy, the National Assessment on Global Climate Change on the basis of the OMB guidelines. The Environmental Protection Agency (EPA) appears to be one of the main targets of these industry groups in their efforts. While high quality data is important and useful in policy process and decision-making, OMB Watch is worried that this guidance will allow certain stakeholders to bog down EPA's efforts to protect the health and environment of U.S. citizens. EPA, which already has procedures in place to improve data quality, should make specific efforts to structure its guidelines in such a way as to safeguard itself from this potential outcome. The hope is that the data quality process will actually engender greater dissemination of information with constructive efforts to correct errors and improve data after its release. The data quality guidance issued by OMB specifically states that these standards and procedures should not be an impediment to agencies disseminating information to the public. Indeed EPA has a useful integrated error correction process for many of its databases. The mechanism has been up and running for 18 months, receiving over 1,000 correction requests, resulting in 120 actual data corrections. A critical component of this error correction system is the process by which data that has been questioned in an error report is not removed from dissemination but only flagged to acknowledge its status as "under review." This is a case where dissemination has been a boon to data quality by allowing broader efforts to improve the databases. OMB Watch has encouraged EPA to utilize requirements in the administrative mechanisms for correction that would minimize any undue burden on the agency, such as requiring that data challenges be submitted in a timely manner (limit of 90 days after dissemination), submitters establish that they are "an affected party," and explain in what way they have been "harmed." OMB Watch has also urged EPA to model its data quality guidelines on the principles that guided the establishment and operation of its integrated error correction system. EPA should build upon its experience from this system in its efforts to deal with other forms of information outside of databases. It is unlikely that EPA will ever have perfect data or unquestionable scientific information, especially within the resource and time constraints that it must operate to protect human health and the environment. The EPA should be establishing guidelines and procedures that encourage and assist data correction while avoiding removal of data or information. OMB Watch will continue tracking this process of establishing data quality guidance at EPA, as well as at other key agencies, and plans to participate in the process in the future.
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