0567 SS 092310 rev

SUPPORTING STATEMENT
Conflict of Interest Disclosure for Nonfederal Government Individuals Who Are
Candidates to Conduct Peer Reviews
OMB CONTROL NO. 0648-0567
A.

JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.
This request is an extension of the information collection.
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) which 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 three 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, the second form is for
peer reviewers of any other influential scientific information subject to the Peer Review Bulletin,
and the third form is a variation of the second form as adapted by NOAA’s Office of Oceanic
and Atmospheric Research (OAR) for potential reviewers of scientific laboratories. The forms
include questions about employment as well as investment and property interests and research
funding. All three 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, or an OAR laboratory peer
review. The number of peer reviews conducted pursuant to the PRB each year will vary, but for
illustrative purposes, NOAA currently has sixty-seven 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 (there is much less variance in the

1

number of laboratory reviews). 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.
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 to Question 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 NOAA peer review conflict of interest forms are available in Word, downloadable from the
NOAA Office of the Chief Information Officer’s Information Quality Web page:
http://www.cio.noaa.gov/Policy_Programs/info_quality.html and fillable on a computer. The
format allows the user to electronically complete and sign the form, then email it and his/her CV
to the NOAA office conducting the peer review. A paper copy of the OAR lab peer review
conflict of interest form (with many fewer responses) is sent to potential reviewers along with
the invitation to participate in a 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 only.
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. While the OAR laboratory conflict of interest disclosure is not under the

2

authority of the OMB PRB requirements, it affords a standardized, comprehensive means of
addressing an equally necessary part of their peer review process.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
NA.
8. Provide information on 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 published on July 13, 2010 (75 33914) solicited comments on this
renewal. No comments were received.
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
scientific assessments, the reviewer’s credentials and relevant experience must also be disclosed,
as required by the PRB. Although the OAR laboratory reviews are not subject to the PRB, the
same procedures are followed, but with the disclosure of the reviewer’s credentials and relevant
experience not applicable for these reviews.

3

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: 312 (300 for the NOAA peer reviews and 12 for the OAR
lab peer reviews).
Estimated Time Per Response: 30 minutes.
Estimated Total Annual Burden Hours: 156.
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 Question
12 above).
There are no recordkeeping/reporting costs to the respondernts.
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: 156 (30 minutes x 312 forms).
Estimated annual cost to federal government (156 hours x $40.00/hr): $6,240.00.
15. Explain the reasons for any program changes or adjustments.
There are no changes in burden or cost.
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.
NA.
18. Explain each exception to the certification statement.
NA.

4

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
This collection does not employ statistics.

5