Draft citation policy — submissions
The 9 submissions received, published in full with declared interests and secretariat responses.
§2Submissions and responses
9 submissions were received. Each is published in full below with its declared interest, the secretariat response and the disposition. The Institute publishes submissions it did not accept in the same form as those it did.
The position of a contributor who withdraws consent is not stated
The respondent states that consent to be named is obtained at submission and that the policy is silent on what happens if it is later withdrawn, which leaves both the Institute and the contributor without a rule.
The respondent proposes that the position be stated in advance and be the same for everyone.
The secretariat accepts this submission. A rule made at the point of the first withdrawal is a rule made about a particular person.
The policy now states that a contributor may withdraw from the register at any time and that the register entry is removed, while a signed submission already published remains published, because the consultation record is a record of what was said and by whom. The position is stated at the point consent is given.
Point estimates are given without an interval
Several estimates in the draft appear as single figures. The respondent states that a point estimate without an interval invites a precision the underlying data do not support, and that the effect is worst where the estimate is drawn from a small contributing set.
The respondent proposes that no point estimate appear anywhere in the document set without its interval, including in summary tables and in the abstract.
The secretariat accepts this submission in part. Intervals are added wherever the source reports one. The proposal is declined for figures the source published without an interval, because the Institute will not compute an interval a source did not report.
Every estimate now carries its interval where the source reported one, and where it did not, the estimate is annotated as reported without an interval rather than left to appear as a precise figure.
The document set should be published in translation
The respondent notes that the assessments concern compounds supplied internationally and that publishing only in English restricts access to the assessment to readers who work in it.
The respondent proposes machine translation of the document set as an interim measure, with human review of the certainty language.
The secretariat does not accept this submission, and records that the underlying point is sound and that the proposed remedy is the difficulty.
A translation whose certainty language has drifted is a different assessment carrying the Institute's name, and the Institute cannot review translations it does not have the capacity to review. The documents remain in English. The submission is published in full because the access problem it identifies is real and unresolved.
Anonymous submissions should be accepted where the respondent risks employment consequences
The respondent states that people in a position to identify a defect in a manufacturer's documentation are frequently employed by that manufacturer, and that requiring a signature excludes exactly those submissions.
The respondent proposes an anonymous route with verification held by the secretariat and not published.
The secretariat does not accept this submission, and records that the exclusion it identifies is real.
The Institute publishes no anonymous submission, because a submission whose author is not published cannot be weighed against a declared interest and the declaration is the mechanism the whole surface rests on. Material bearing on a factual defect may instead be submitted to the evidence log, where it is assessed on the document and the submitter is named only with consent. The submission remains published in full.
Whether external reviewers are paid is not stated
The respondent states that payment or its absence bears on who is able to review and on what the Institute may expect of them, and that the policy does not address it.
The respondent proposes that the position be stated and that any payment be disclosed at the level of the individual document.
The secretariat accepts this submission. Payment is an interest and the policy treats interests as facts to be published.
The policy now states whether external review is remunerated, records any payment made in respect of a document in that document's front matter, and treats a payment received from the Institute as a declarable interest in the same way as any other.
The policy does not say what happens to a document the Institute is asked to remove
The respondent states that assessments of named parties will attract removal requests, and that a policy silent on them will be applied inconsistently under pressure.
The respondent proposes that the grounds on which a document may be withdrawn be stated in advance and be exhaustive.
The secretariat accepts this submission. A policy written after the first request will be written under the conditions least suited to writing it.
The grounds for withdrawal are now stated exhaustively, being a factual error that cannot be corrected in place and a legal obligation, a withdrawn document is replaced by a notice recording the fact and the ground rather than removed, and every withdrawal is recorded in the corrections log.
The materiality threshold for a declarable holding is set too high
The respondent states that the threshold in the draft excludes holdings a reader would regard as relevant, and that the cost of declaring a small holding is negligible against the cost of a reader discovering an undeclared one.
The respondent proposes that all holdings be declared regardless of size.
The secretariat accepts this submission in part. The threshold is lowered. Declaration of every holding without threshold is not adopted, because an undifferentiated list obscures the holdings that matter.
The materiality threshold is lowered and is now expressed as a proportion of the declarer's holdings as well as an absolute figure, so that a holding material to the person is declarable whether or not it is large in absolute terms.
The search date is not on the face of the document
The draft carries a publication date and a review date but not the date on which the evidence was last searched. Those are three different dates and only the third tells a reader how current the assessment is. A document published in one quarter may rest on a search run two quarters earlier, and nothing on the page allows that gap to be measured.
The respondent proposes that the search date be printed adjacent to every certainty rating rather than in the methods section, on the ground that a reader who acts on a rating is unlikely to have read the methods section first.
The secretariat accepts this submission. The distinction between publication, review and search dates is real and the draft did not make it visible where it mattered.
The search date is now printed adjacent to every certainty rating and is carried in the document metadata, so that the interval between the search and the reading is visible without reference to the methods section.
Funding should not be accepted from any party the Institute assesses
The respondent states that disclosure does not neutralise an incentive, and that accepting funding from an assessed party creates one whether or not it is acted on.
The respondent proposes an outright prohibition on funding from any assessed supplier or manufacturer.
The secretariat accepts this submission in part. Funding from an assessed party is not accepted for assessment work. A general prohibition covering all activity is not adopted, because it would extend to unrestricted contributions the Institute can accept without any assessment consequence.
The policy now prohibits funding from an assessed party for any activity bearing on that party's assessment, requires that any other relationship be published on the funding page and on every page it could bear on, and records the sums involved rather than the fact of a relationship alone.
References cited on this page
References are numbered in order of first citation in this document. Each superscript in the text links to its entry below.
- International Organization for Standardization. ISO/IEC 17025:2017 General Requirements for the Competence of Testing and Calibration Laboratories. ISO/IEC Standard 2017;3rd edition. identifier not held by the Institute
Identifiers are reproduced only where the Institute holds them. Where a digital object identifier or PubMed identifier is not shown, the Institute has recorded the journal and year and has not constructed an identifier.