IFT Comments on Public Access Policies for Science and Technology Funding Agencies across the Federal Government

January 13, 2010

Office of Science and Technology Policy Executive Office of the President Attn: Open Government Recommendations 725 17th Street Washington, DC 20502

Re: Public Access Policies for Science and Technology Funding Agencies across the Federal Government [DOCID: fr09de09-111]

Dear Sir or Madam:

The Institute of Food Technologists appreciates the opportunity to comment on public access policies for science and technology funding agencies across the federal government. Founded in 1939, IFT is a not-for-profit scientific society with more than 18,500 individual members working in food science, technology and related professions. IFT is pleased to be invited to offer comment on the availability of knowledge of research through scientific and technical publications because IFT is committed to the free flow of scientific information. IFT serves its members, affiliated with academia, industry, and government, and all those interested in food science and technology by publishing three internationally renowned peer-reviewed journals and a technical magazine. As a publisher, IFT assembles more than 1000 preeminent food scientists, technologists, and engineers among our comprehensive pool of peer reviewers. Such an extensive resource of peer reviewers ensures that the research made available to the scientific community is important, comprehensive, and of high quality and integrity.

Two of IFT's peer-reviewed e-publications (Journal of Food Science Education and Comprehensive Reviews in Food Science and Food Safety) are currently freely available online. In addition, the Journal of Food Science is available to IFT members at a discounted subscription rate and to others on a per article download charge or through subscription. Food Technology magazine, published monthly, is available to IFT members in print and online. The online version of Food Technology is initially available free to the public for about one month, and then becomes accessible only to IFT members. To ensure that the public is informed of research findings, IFT, along with publishing partner Wiley-Blackwell, has a well-organized system to promote particularly newsworthy research through popular media and news releases.

Based on our 60-plus year history of scientific publishing, IFT strongly believes that the current system for handling and releasing peer-reviewed research—federally-funded or otherwise—is not broken and does not need a federally-mandated open access policy. Specific points were presented in the OSTP Request for Information as justification for a statement on the need for increased public access to research resulting from federallyfunded projects. IFT offers below responses to these points; additional comments follow.

“(a) More timely, easier, and less costly access to scholarly publications resulting from federally funded research for commercial and noncommercial scientists has the potential to promote advances in science and technology, thereby enhancing the return on federal investment in research;”

This rationale assumes that there are scientists who are restricted in their access to research. To date, IFT is not aware of any definitive studies that validate this hypothesis. Surely implementation of a policy that would have the unintended consequence of irreparable harm to the peer review system would not be undertaken without sound scientific data to justify the action. The peer review system functions through scientific journals, many of which are supported through scientific societies by subscriptions from individuals, libraries, and corporate entities. Mandatory release of research at the time a manuscript is accepted for publication would undermine subscriptions and result in loss of revenue for carrying out the peer review activity.

“(b) Creating an easily searchable permanent electronic archive of scholarly publications resulting from federally funded research has the potential to allow cross-referencing, continuous long-term access, and retrieval of information whose initial value may only be theoretical, but may eventually have important applications;”

The creation of such a searchable database should be readily attainable now with the information that federal agencies have on their funded projects. Principal investigators are required to submit references to all research published under a federal grant or contract (unless there are reasons of national security for not doing so). These reports and publications could easily be assembled now into a searchable database obviating the need to require further release of published materials.

“(c) Ensuring that the federal agencies that support this research can access the published results has the potential to promote improved cross-government coordination of government funding, and thus improved management of the federal research investments;”

As stated above, federal agencies now have all the data and can assemble such a searchable database. Requiring open access of a manuscript immediately after acceptance by a journal is not necessary to improve management of federally-funded research programs.

“(d) More timely, easier, and less costly access to scholarly publications resulting from federally funded research for educators and students, and ‘end users’ of research, such as clinicians, patients, farmers, engineers, and practitioners in virtually all sectors of the economy, has the potential to promote the diffusion of knowledge.”

As stated in (a) above, there has been no definitive study showing that those with interest in a particular research topic are now unnecessarily restricted in their access to the scientific data and results. Thus, there is no reason to hypothesize that such a government run database would enhance access or be more useful than current searchable databases.

Additional Comments:

Much of the discussion around the issue of public access was fueled by an NIH decision in February, 2005. In its “Policy on Enhancing Public Access to Archived Publications Resulting from NIH-funded Research,” NIH-funded researchers were requested to submit electronic versions of the author’s final manuscript upon acceptance for publication to PubMed Central to be released to the public as soon as possible and within 12 months of the publisher’s official date of final publication. IFT is not aware of any studies on the effectiveness of this voluntary open access model.

Perhaps the most important quality that can be attributed to a research publication is whether or not it has been subjected to peer review. Peer review is carried out through the auspices of the publisher, and its associated costs are borne primarily through subscriptions. If the publisher is a professional scientific society, as IFT is, however, some expenses may be borne through member dues as a member service. In either case the costs associated with handling the manuscript including peer review and copy editing are real costs. Without some grace period prior to free access, the publisher will be forced to charge the authors page charges (which some publishers now do). Such a move is likely to delay publication of research results, an unintended consequence of a public access policy.

In conclusion, IFT is committed to the free flow of scientific information, as demonstrated in offering its two peer-reviewed e-publications free of charge. In addition, the Journal of Food Science prides itself on having an enviable impact factor rating and a receipt-to-final publication time frame of only 55 days. An assembly of more than 1000 scientists, with the most preeminent food scientists and engineers in the food science and technology profession, is included in the peer reviewer listing. In this way, IFT ensures that impactful research of high quality and integrity is available to the scientific community. IFT, along with its publishing partner Wiley-Blackwell, has a wellorganized system to promote this research through popular media and news releases. IFT believes that the current system for handling and releasing peer-reviewed research that is either federally funded or otherwise is not broken and does not need a federally-mandated open access policy.

IFT looks forward to continuing to contribute to this important public debate and decision.

Sincerely,

Daryl B. Lund, Ph.D. Editor-in-Chief, IFT Scientific Journals

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