The Federalist Society

Independent Peer Review: The Sine Qua Non of Information Quality

April 1, 2004

Jeffrey Ladik

In September 2003, the Office of Management and Budget’s (OMB) Office of Information and Regulatory Affairs (OIRA) published a notice in the Federal Register that proposed new guidance regarding independent peer review of federal agency scientific and technical information, and also asked for comments. The OMB notice states that existing agency peer review mechanisms have not always been sufficient to ensure the reliability of regulatory information disseminated or relied upon by federal agencies.2 OMB is entirely correct in its assessment of the challenges agencies face in developing highquality and objective information that is used in regulatory decision making. Independent peer review, if properly conducted, would add integrity and transparency to the regulatory process. Equally important, Congress requires OMB to issue peer review guidelines.

Independent Peer Review: The Sine Qua Non of Information Quality  


The Federalist Society