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CDC —Trans Fats - b2

HHS Information Quality Web Site
Information Requests for Corrections and HHS' Responses
Response to RFC

December 19, 2014


Daren Bakst
Research Fellow in Agricultural Policy
Thomas A. Roc Institute for Economic Policy Studies
The Heritage Foundation


Dear Mr. Bakst:

This letter is in response to your request to correct information contained in the Winnable Battles Progress Report: 2010-2015, (Report) dated September 9th, 2014. The purpose of the Report was to document progress on key public health indicators. The study as referenced in the Report is "Eliminating the Use of Partially Hydrogenated Oil in Food Production and Preparation" (Paper) published in Journal of the American Medical Association in July, 2012. The Paper was authored by William Dietz and Kelley Scanlon who were CDC employees at the time it was developed. The Paper was reviewed and approved by CDC following the standard agency clearance protocol.

As you note in your letter, the Paper itself contained the following disclaimer statement: "The findings and conclusions in this report are those of the authors and do not necessarily reflect the official position of the US Centers for Disease Control and Prevention." In most cases, Health and Human Services (HHS) employees are encouraged to use such a disclaimer in publications. This policy is consistent with the requirements of the OMB Information Quality Peer Review Bulletin. The Paper underwent external peer review as part of the CDC review process and then was subjected to peer review by the Journal of the American Medical Association, a widely respected, scientific refereed journal. This process conformed to CDC Information Quality Guidelines.

The presence of a disclaimer statement does not prevent CDC or any other HHS agency from subsequently using the information from such publications in progress reports and other publications. In developing the "Winnable Battles Progress Report: 2010-2015", the agency used the conclusions in the paper "Eliminating the Use of Partially Hydrogenated Oil in Food Production and Preparation" to inform the statement regarding the impact of eliminating added trans fats. The Winnable Battle Progress Report text will be edited to clarify that the information was from the peer reviewed literature and the appropriate reference will be provided.

In conclusion, CDC believes the reference to the Paper authored by CDC staff members is consistent with requirements of the Information Quality Act. To clarify the source of the information included in the Winnable Battles Progress Report, the appropriate reference to the Paper will be provided and the language will be modified to indicate that the statement is based on peer reviewed research. 

If you wish to appeal this response to your request for correction, you may submit a written appeal or electronic request for reconsideration within 30 days of receipt of our response. The appeal must state the reasons why the agency response is insufficient or inadequate. You must attach a copy of your original request and the agency's response to it. Also, clearly mark the appeal with the words, "Information Quality Appeal" and send the appeal to the following address:

Centers for Disease Control and Prevention
Management Analysis and Services Office
1600 Clifton Road, NE, Mailstop F-07
Atlanta, Georgia 30333 Fax: (770) 488-4995 or Electronic Mail:


Deborah Galuska
Associate Director for Science
Division of Nutrition, Physical Activity, and Obesity
Centers for Disease Control and Prevention