Peer Review SS_051407corr

SUPPORTING STATEMENT
Conflict of Interest Disclosure for Nonfederal Government Individuals Who Are
Candidates to Conduct Peer Reviews Required by the OMB Peer Review Bulletin
OMB CONTROL NO. 0648-xxxx

A.

JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.
The Office of Management and Budget (OMB) issued government-wide guidance to enhance the
practice of peer review of government science documents: OMB’s Final Information Quality
Bulletin for Peer Review (“Peer Review Bulletin” or PRB) establishes minimum peer review
standards for influential scientific information that federal agencies intend to disseminate. The
PRB also directs federal agencies to adopt or adapt the National Academy of Sciences (NAS)
policy for evaluating conflicts of interest when selecting peer reviewers who are not federal
government employees (federal employees are subject to federal ethics requirements which
address conflict of interest). For peer review purposes, the term “conflict of interest” means any
financial or other interest which conflicts with the service of the individual because it could: (1)
significantly impair the individual’s objectivity; or (2) create an unfair competitive advantage for
any person or organization.
NOAA has adapted the NAS policy and developed two confidential conflict of interest
disclosure forms which the agency will use to examine prospective reviewers’ potential financial
conflicts and other interests that could impair objectivity or create an unfair advantage. One
form is for peer reviewers of studies related to government regulation and the other form is for
peer reviewers of any other influential scientific information subject to the Peer Review Bulletin.
The forms include questions about employment as well as investment and property interests and
research funding. Both forms also require the submission of a curriculum vitae (CV).
2. Explain how, by whom, how frequently, and for what purpose the information will be
used. If the information collected will be disseminated to the public or used to support
information that will be disseminated to the public, then explain how the collection
complies with all applicable Information Quality Guidelines.
NOAA is seeking to collect this information from potential peer reviewers (non-government
employees) when conducting a peer review pursuant to the PRB. The number of peer reviews
conducted pursuant to the PRB each year will vary, but for illustrative purposes, NOAA
currently has forty-five peer review plans posted on its Peer Review Agenda, indicating that
forty-five agency products were recently completed, are presently undergoing, or are planning to
begin peer review. The information collected in the conflict of interest disclosure is essential to
NOAA’s compliance with the OMB PRB, and helps to ensure that government studies are
reviewed by independent, impartial peer reviewers.

1

As explained in the preceding paragraphs, the information gathered has utility. NOAA will
retain control over the information and safeguard it from improper access, modification, and
destruction, consistent with NOAA standards for confidentiality, privacy, and electronic
information. See response #10 of this Supporting Statement for more information on
confidentiality and privacy. The information collection is designed to yield data that meet all
applicable information quality guidelines. Although the information collected is not expected to
be disseminated directly to the public, results may be used in scientific, management, technical
or general informational publications. Should NOAA be required to release any of the
information, it will be subject to the quality control measures and pre-dissemination review
pursuant to Section 515 of Public Law 106-554.
3. Describe whether, and to what extent, the collection of information involves the use of
automated, electronic, mechanical, or other technological techniques or other forms of
information technology.
The conflict of interest forms will be available in Word or PDF formats, downloadable from the
NOAA CIO’s website. Both formats will allow the user to electronically complete and sign the
form, then email it and his/her CV to the NOAA office conducting the peer review.
4. Describe efforts to identify duplication.
This information collection is specifically required by OMB’s Peer Review Bulletin. Each
potential peer reviewer is asked to disclose any potential conflicts with regard to a given study.
NOAA will not ask that the potential reviewer complete more than one conflict form per study.
5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
The information collection involves individuals. The forms can be completed electronically,
reducing the time required to complete the task. Additionally, potential peer reviewers will be
directed to provide a copy of their CV which will be used in conjunction with the disclosure
form to evaluate the potential for conflicts of interest, thus reducing the burden on potential
reviewers who would otherwise be required to duplicate information already available from their
CVs concerning organizational affiliations, government service and research support relevant to
the peer review panel on which they are being asked to serve.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
If the collection is not completed, NOAA would be in violation of OMB’s PRB requirements for
screening potential peer reviewers for conflicts of interest. Alternatively, the agency would not
be able to solicit non-governmental peer reviewers, a practice which would be contrary to the
clear intent of the PRB.

2

7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
None.
8. Provide a copy of the PRA Federal Register notice that solicited public comments on the
information collection prior to this submission. Summarize the public comments received
in response to that notice and describe the actions taken by the agency in response to those
comments. Describe the efforts to consult with persons outside the agency to obtain their
views on the availability of data, frequency of collection, the clarity of instructions and
recordkeeping, disclosure, or reporting format (if any), and on the data elements to be
recorded, disclosed, or reported.
A federal register notice was published on December 8, 2006. One comment was received. It
alleged systemic conflicts of interest in the commercial fishing industry, NOAA and Congress.
The agency believes the allegations are unsubstantiated and lack merit. However, the proposed
information collection is designed to identify and prevent conflicts of interest, including financial
conflicts of interest in the review of influential scientific information disseminated by the
agency.
As OMB has recognized in the PRB, NAS has extensive experience in conducting peer review of
government information. The NOAA conflict of interest disclosure forms are adapted from the
forms used by NAS. In adapting the NAS forms, changes were kept to the minimum required to
apply the NAS standards on conflicts while reducing the burden on potential peer reviewers as
much as possible. Therefore, the clarity of instructions, reporting format and data elements to be
disclosed are of high quality.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payment or gift will be made to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
NOAA’s Policy on Conflicts of Interest for Peer Review subject to the OMB Peer Review
Bulletin states that, except as provided for in the Policy, specific conflict of interest information
obtained by NOAA – or the entity commissioned by NOAA to manage the peer review process –
from: 1) the NOAA conflict of interest disclosure form, 2) amended disclosures, and 3) the
public and other sources will be held in confidence by NOAA. Access to such information
within NOAA will be limited to those offices whose proper business requires access to that
information. Such information will not be released by NOAA, or the entity commissioned by
NOAA to manage the peer review process, except with the approval of the individual to whom
the information pertains, unless release is required by law. As specified in NOAA’s Policy on
Conflicts of Interest, the exception to the non-disclosure policy is the public disclosure of the
names of reviewers and their organizational affiliations. For peer reviewers of highly influential

3

scientific assessments, the reviewer’s credentials and relevant experience must also be disclosed,
as required by the PRB.
11. Provide additional justification for any questions of a sensitive nature, such as sexual
behavior and attitudes, religious beliefs, and other matters that are commonly considered
private.
There are no questions of this type in the forms. They ask only about financial, investment,
property, employment, or research funding interests in the study to be peer reviewed.
12. Provide an estimate in hours of the burden of the collection of information.
Estimated Number of Respondents: 300
Estimated Time Per Response: 30 minutes
Estimated Total Annual Burden Hours: 150.
13. Provide an estimate of the total annual cost burden to the respondents or recordkeepers resulting from the collection (excluding the value of the burden hours in #12
above).
The forms can be downloaded, completed, and signed electronically, and the forms and required
attachments can be emailed, so it is not necessary that potential peer reviewers incur printing or
postage expenses.
14. Provide estimates of annualized cost to the Federal government.
Estimated time for government staff (GS 13) to review each completed conflict of interest form:
30 minutes
Estimated total annual government staff hours: 150 (30 minutes x 300 forms)
Estimated annual cost to federal government (150 hours x $40.00/hr): $6,000.00.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or
14 of the OMB 83-I.
This is a new collection.
16. For collections whose results will be published, outline the plans for tabulation and
publication.
The collection will not be published.
17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons why display would be inappropriate.
None.

4

18. Explain each exception to the certification statement identified in Item 19 of the
OMB 83-I.
None.
B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
This collection does not employ statistics.

5