The public has the right to know the basis for government policy and regulations. The law and rule simply codify basic principles of the scientific method concerning the sharing of data that may be necessary for verifying the scientific grounds for government policy and rules. Congress had requested the data so that the studies' results could be independently confirmed.
Epidemiologic data differ from experimental and laboratory data.
While disclosure of materials and methods usually provides sufficient information for attempted replication of experimental and laboratory studies, this is insufficient in epidemiology. Epidemiologic data are collected from populations of people, and no two populations are alike. Given that many studies used to support government policy and rules report results at the edge of epidemiology's credibility, examination of those studies requires access to the same data set. Dr. Alberts' letter, written on behalf of the Council of the National Academy of Sciences and sent one week before OMB proposed the rule, flatly opposes the new law. Dr. Alberts' letter largely ignores its intent and scope.