**Data Quality Act Documentation and Pre-Dissemination Review
Guidelines**

**Background**

Section 515 of the Treasury and General Government Appropriations Act
for Fiscal Year 2001 (Public Law 106-554) directed the Office of
Management and Budget (OMB) to issue government-wide guidelines that
"provide policy and procedural guidance to federal agencies for ensuring
and maximizing the quality, objectivity, utility, and integrity of
information (including statistical information) disseminated by federal
agencies." OMB complied by issuing guidelines which direct each federal
agency to 1) issue its own guidelines; 2) establish administrative
mechanisms allowing affected persons to seek and obtain correction of
information that does not comply with the OMB 515 Guidelines or the
agency guidelines; and 3) report periodically to OMB on the number and
nature of complaints received by the agency and how the complaints were
handled. The OMB Guidelines can be found at:

[[http://www.whitehouse.gov/omb/fedreg/reproducible2.pdf]{.underline}](http://www.whitehouse.gov/omb/fedreg/reproducible2.pdf)

The Department of Commerce Guidelines can be found at:
[[http://www.osec.doc.gov/cio/oipr/iqg.htm]{.underline}](http://www.osec.doc.gov/cio/oipr/iqg.htm)

The NOAA Section 515 Information Quality Guidelines, created with input
and reviews from each of the components of NOAA Fisheries, went into
effect on October 1, 2002. **The NOAA Information Quality Guidelines are
posted on the NOAA home page under "Information Quality."
[[http://www.noaanews.noaa.gov/stories/iq.htm]{.underline}](http://www.noaanews.noaa.gov/stories/iq.htm)**

The guidelines apply to a wide variety of government information
products and all types of media, including printed, electronic,
broadcast or other. The guidelines define "Information" as, "any
communication or representation of knowledge such as facts or data, in
any medium or form, including textual, numerical, graphic, cartographic,
narrative, or audiovisual forms." For example, this definition includes
information that an agency disseminates from a web page. The guidelines
define "Dissemination" as, "agency initiated or sponsored distribution
of information to the public." Explicitly **not** included within this
term is distribution limited to "government employees or agency
contractors or grantees; intra- or inter-agency use or sharing of
government information; and responses to requests for agency records
under the Freedom of Information Act, the Privacy Act, the Federal
Advisory Committee Act or other similar law." It also does not include
distribution limited to correspondence with individuals or persons,
press releases, archival records, public filings, subpoenas or
adjudicative processes."

To assist in Data Quality Act compliance, NOAA Fisheries has established
a series of actions that should be completed for each new information
product subject to the Data Quality Act. **In addition to the
information contained in this document, familiarity with the NOAA
Section 515 Information Quality Guidelines
([[http://www.noaanews.noaa.gov/stories/iq.htm)]{.underline}](../(http://www.noaanews.noaa.gov/stories/iq.htm))
is crucial for NOAA Fisheries employees who engage in the generation and
dissemination of information.**

[Information Generation and Compliance Documentation]{.underline}

> • The fundamental step in the process is to create a Sec. 515
> Information Quality file for each new information product. To aid in
> this process, a Data Quality Act Pre-Dissemination Review and
> Documentation form has been created. The basic steps to the
> documentation process are listed below.
>
> • Complete general information (e.g., author/responsible office,
> title/description) section of the form.
>
> • Determine the information category (i.e., original data; synthesized
> products; interpreted products; hydrometeorological, hazardous
> chemical spill, and space weather warnings, forecasts, and advisories;
> experimental products; natural resource plans; corporate and general
> information). **For most information products, you will only need to
> check one box.** More complex documents may be an "aggregate" of
> different categories of information products.
>
> • Generate the information in a way that meets each of the applicable
> standards for the appropriate information category. See the NOAA
> Information Quality Guidelines.
>
> • Document how the standards for **utility, integrity** and
> **objectivity** are met for each information product, describing what
> measures were taken to meet each of the applicable standards.

• Maintain the Sec. 515 Information Quality file in a readily accessible
place.

[Pre-Dissemination Review]{.underline}

> • Before information is disseminated, it must be reviewed for
> compliance with the NOAA Sec. 515 Information Quality Guidelines. This
> is accomplished by reviewing the information [and]{.underline} the
> Sec. 515 Information Quality file.
>
> • The person conducting the Pre-Dissemination Review will sign and
> date the Pre-Dissemination Review & Documentation Form.
>
> • The Pre-Dissemination Review form and the supporting information
> quality documentation must accompany the information product through
> the clearance process and be maintained on file.

**Completing the DQA Pre-Dissemination Review & Documentation Form**

Document how the information product meets the following standards for
**Utility, Integrity** and **Objectivity.**

I.  **Utility of Information Product**

Utility means that disseminated information is useful to its intended
users. "Useful" means that the content of the information is helpful,
beneficial, or serviceable to its intended users, or that the
information supports the usefulness of other disseminated information by
making it more accessible or easier to read, see, understand, obtain or
use.

A. Is the information helpful, beneficial or serviceable to the intended
user? Explain.

> B. Who are the intended users of the data or information product?
> (e.g., the American public; other federal agencies; state and local
> governments; recreational concerns; national and international
> organizations). Is this data or information product an improvement
> over previously available information? Is it more detailed or current?
> Is it more useful or accessible to the public? Has it been improved
> based on comments or interactions with users?
>
> C. What media are used in the dissemination of the information?
> Printed publications? CD-ROM? Internet?

Is the product made available in a standard data format?

> Does it use consistent attribute naming and unit conventions to ensure
> that the information is accessible to a broad range of users with a
> variety of operating systems and data needs?

II. **Integrity of Information Product**

Integrity refers to security - the protection of information from
unauthorized access or revision, to ensure that the information is not
compromised through corruption or falsification. Prior to dissemination,
NOAA information, independent of the specific intended distribution
mechanism, is safeguarded from improper access, modification, or
destruction, to a degree commensurate with the risk and magnitude of
harm that could result from the loss, misuse, or unauthorized access to
or modification of such information.

Document (circle) how the information product meets the following
standards for integrity:

> A. All electronic information disseminated by NOAA adheres to the
> standards set out in Appendix III, "Security of Automated Information
> Resources," OMB Circular A-130; the Computer Security Act; and the
> Government Information Systems Reform Act.
>
> B. If information is confidential, it is safeguarded pursuant to the
> Privacy Act and Titles 13, 15, and 22 of the U.S. Code
> (confidentiality of census, business and financial information).

C. Other/Discussion

> (e.g., 50 CFR 600, Subpart E, Confidentiality of Statistics of the
> Magnuson-Stevens Fishery Conservation and Management Act; NOAA
> Administrative Order 216-100, Protection of Confidential Fisheries
> Statistics; 50 CFR 229.11, Confidentiality of information collected
> under the Marine Mammal Protection Act.)

III. **Objectivity of Information Product**

\(1\) Indicate which one of the following categories of information
products apply for this product (check one):

1.  Original Data - go to Section A

2.  Synthesized Products - go to Section B

3.  Interpreted Products - go to Section C

4.  Hydrometeorological, Hazardous Chemical Spill, and Space Weather
    Warnings, Forecasts, and Advisories - go to Section D

5.  Experimental Products - go to Section E

6.  Natural Resource Plans - go to Section F

7.  Corporate and General Information - go to Section G

\(2\) Document how this information product meets the applicable
objectivity standards.

[General Standard]{.underline}: Information is presented in an accurate,
clear, complete, and unbiased manner, and in proper context. The
substance of the information is accurate, reliable, and unbiased; in the
scientific, financial or statistical context, original and supporting
data are generated and the analytical results are developed using sound,
commonly accepted scientific and research methods. "Accurate" means that
information is within an acceptable degree of imprecision or error
appropriate to the particular kind of information at issue and otherwise
meets commonly accepted scientific, financial and statistical standards.

If the information is "influential," that is, it is expected to have a
genuinely clear and substantial impact on major public policy and
private sector decisions, it is noted as such and it is presented with
the highest degree of transparency. If influential information
constitutes an assessment of risks to human health, safety or the
environment, indicate whether the risk assessment was qualitative or
quantitative, and describe which SDWA-adapted quality standards at page
9 of NOAA's Section 515 Information Quality Guidelines were applied to
the information product.

Use of third party information in the product (information not collected
or generated by NOAA) is only done when the information is of known
quality and consistent with NOAA's Section 515 Guidelines; any
limitations, assumptions, collection methods, or uncertainties
concerning the information are taken into account and disclosed.

[Specific Standards]{.underline}: Specific objectivity standards for
categories of information products disseminated by NOAA are listed
below. Document how the general and specific objectivity standards for
the particular information product were met.

A.  **[Original Data]{.underline}**

Objectivity of original data is achieved using sound quality control
techniques.

> Detail how the data collection methods, systems, instruments,
> training, and/or tools are appropriate to meet the requirements of the
> intended users.

Were the methods, systems, instruments, etc., validated before use?

> Were standard operating procedures (SOPs) followed for time series
> data collections? If not, document the valid scientific reasons for
> the deviation.

Document the quality control techniques used, for example:

• Gross error checks for data that fall outside of physically realistic
ranges (e.g., a minimum, maximum or maximum change)

1.  Comparisons made with other independent sources of the same
    measurement

2.  Examination of individual time series and statistical summaries

3.  Application of sensor drift coefficients determined by a comparison
    of pre- and post-deployment calibrations

4.  Visual inspection of data

> Describe any evolution and/or improvements in survey techniques,
> instrument performance and/or data processing.
>
> Have metadata record descriptions and explanations of the methods and
> quality controls to which original data are subjected been included in
> the disseminated product? If not, are they available upon request?

B.  **[Synthesized Products]{.underline}**

The objectivity of synthesized products is achieved by using data of
known quality, applying sound analytical techniques, and reviewing the
products or processes used to create them before dissemination. For
synthesized products, please document the following:

> Identify data sources (preferred option) or be prepared to make them
> available upon request.
>
> Are the data used of known quality or from sources acceptable to the
> relevant scientific and technical communities?
>
> Are the methods used to create the synthesized product published in
> standard methods manuals or generally accepted by the relevant
> scientific and technical communities?

Are the methods documented in readily accessible formats by the
disseminating office?

> Describe the review process used to ensure the validity of the
> synthesized product or the procedures used to create them, e.g.,
> statistical procedures, models, or other analysis tools.
>
> If the synthesized product is unique or not regularly produced, was
> this product reviewed by internal and/or external experts?
>
> If this is a routinely produced synthesized product, was the process
> for developing the product reviewed by internal and/or external
> experts?
>
> Does the synthesized product include information about the methods
> used to create the product? If not, the methods must be made available
> upon request.

C.  **[Interpreted Products]{.underline}**

Objectivity of interpreted products is achieved by using data of known
quality or from sources acceptable to the relevant scientific and
technical communities and reliable supporting products, applying sound
analytical techniques, presenting the information in the proper context,
and reviewing the products before dissemination.

Are all data and information sources identified or properly referenced?

> Are the methods used to create the interpreted product generally
> accepted by the relevant scientific and technical communities?
>
> Is information concerning the quality and limitations of the
> interpreted product provided to help the user assess the suitability
> of the product for the user's application?
>
> Document the review process used to ensure that the product is valid,
> complete, unbiased, objective and relevant. For example, peer reviews,
> ranging from internal peer review by staff who were not involved in
> the development of the product to formal, independent, external peer
> review. The review should be conducted at a level commensurate with
> the importance of the interpreted product.
>
> Does the interpreted product include a description of the methods used
> to create the product? If not, can it made available upon request?

D.  **[Hydrometeorological, Hazardous Chemical Spill, and Space Weather
    Warnings, Forecasts, and Advisories]{.underline}**

Objectivity of information in this category is achieved by using
reliable data collection methods and sound analytical techniques and
systems to ensure the highest possible level of accuracy given the time
critical nature of the products.

> Are the data used of known quality or from sources acceptable to the
> relevant scientific and technical communities?
>
> What is the source of the data or information used in the product? Are
> the sources included in the information product? If not, be prepared
> to make them available upon request.
>
> Are the methods used to create the product generally accepted by the
> relevant scientific and technical communities?
>
> Please note if individual best judgment was used due to the
> time-critical nature of the product.

What mechanisms were used to evaluate the accuracy of the information
product?

Statistical analysis may be carried out for a subset of products for
verification purposes.

E.  **[Experimental Products]{.underline}**

Experimental Products are either:

1\) disseminated for experimental use, evaluation or feedback, or

> 2\) used in cases where, in the view of qualified scientists who are
> operating in an urgent situation in which the timely flow of vital
> information is crucial to human health, safety, or the environment,
> the danger to human health, safety, or the environment will be
> lessened if every tool available is used.
>
> Objectivity of experimental products is achieved by using the best
> science and supporting studies available, in accordance with sound and
> objective scientific practices, evaluated in the relevant scientific
> and technical communities, and peer-reviewed where feasible.
>
> Describe the science and/or supporting studies used, the evaluation
> techniques used, and note any peer-review of the experimental product.

Were the results of initial tests or evaluations made available where
possible?

> Describe the review, by the appropriate NOAA unit, of the experimental
> products and capabilities documentation, along with any tests or
> evaluations.
>
> Are explicit limitations provided concerning the quality of the
> experimental product?

Is the degree of uncertainty indicated?

> Describe the testing process used, e.g., the experimental product or
> capabilities are used only after careful testing, evaluation, and
> review by NOAA experts, and then are approved for provisional use only
> by selected field offices or other NOAA components. This process is
> repeated as needed to ensure an acceptable and reliable level of
> quality.

F.  **[Natural Resource Plans]{.underline}**

Natural Resource Plans are information products that are prescribed by
law and have content, structure, and public review processes (where
applicable) that will be based upon published standards, e.g.,
Sustainable Fisheries Act, Essential Fish Habitat Provisions, Endangered
Species Act, Marine Mammal Protection Act, National Marine Sanctuary
Management Plan Handbook.

Objectivity of Natural Resource Plans will be achieved by adhering to
published standards, using information of known quality or from sources
acceptable to the relevant scientific and technical communities,
presenting the information in the proper context, and reviewing the
products before dissemination.

What published standard(s) governs the creation of the Natural Resource
Plan?

Does the Plan adhere to the published standards?

> (See the NOAA Sec. 515 Information Quality Guidelines, Section II(F)
> for links to the published standards for the Plans disseminated by
> NOAA.)
>
> Was the Plan developed using the best information available?

Please specify.

> Have clear distinctions been drawn between policy choices and the
> supporting science upon which they are based? Have all supporting
> materials, information, data and analyses used within the Plan been
> properly referenced to ensure transparency?
>
> Describe the review process of the Plan by technically qualified
> individuals to ensure that the Plan is valid, complete, unbiased,
> objective and relevant. For example, internal review by staff who were
> not involved in the development of the Plan to formal, independent,
> external peer review. The level of review should be commensurate with
> the importance of the Plan and the constraints imposed by legally
> enforceable deadlines.

G.  **[Corporate and General Information]{.underline}**

Corporate and general information disseminated by NOAA must be presented
in a clear, complete, and unbiased manner, and in a context that
enhances usability to the intended audience. To the extent possible,
identify the sources of the disseminated information, consistent with
confidentiality, privacy and security considerations and protections,
and taking into account timely presentation, the medium of
dissemination, and the importance of the information, balanced against
the resources required and the time available.

Information disseminated by NOAA is reliable and accurate to an
acceptable degree of error as determined by factors such as the
importance of the information, the intended use, time sensitivity,
expected degree of permanence, relation to the primary mission(s) of the
disseminating office, and the context of the dissemination, balanced
against the resources required and the time available.

> For non-scientific, non-statistical information, has the information
> product been reasonably determined to be factually correct in the view
> of the disseminating office as of the time of dissemination?
>
> Describe the review process for the information product. Review can be
> accomplished in a number of ways, including but not limited to
> combinations of the following:

1.  Active personal review of information by supervisory and management
    layers, either by reviewing each individual dissemination, or
    selected samples, or by any other reasonable method.

2.  Use of quality check lists, charts, statistics, or other means of
    tracking quality, completeness, and usefulness.

3.  Process design and monitoring to ensure that the process itself
    imposes checks on information quality .

4.  Review during information preparation.

5.  Use of management controls.

6.  Any other method, which serves to enhance the accuracy, reliability
    and objectivity of the information.