980
Office of Scientific Integrity SIR,-Dan Greenberg’s Washington Perspective (Feb 2, p 289) contains factual errors and elsewhere inaccurately and unfairly characterises the performance of the Office of Scientific Integrity (OSI) of the National Institutes of Health (NIH). The most significant inaccuracies concern the US District Court ruling in the Western District of Wisconsin in Abbs vs Sullivan et al. The court did not rule that the operations of the OSI are "illegal". The Abbs vs Sullivan litigation did not deal with the creation of the OSI but rather with the US Public Health Service’s 1986 (interim) Policies and Procedures for Dealing with Possible Scientific Misconduct. Nor is it correct to say that the judge "sidestepped as moot" due process issues; the issue of whether OSI procedures meet due process requirements was not decided. However, the issue of whether the University of Wisconsin or Dr Abbs had a liberty or property interest sufficient to merit due process was thoroughly examined and decided in favour of the US Government. Moreover, the judge’s ruling noted that the imposition of Public Health Service (PHS) sanctions less than debarment is not subject to determination of cause after a full hearing-that is, the due process required is at the discretion of the Government. Greenberg’s column contains pejorative, unsubstantiated characterisations of the operations of the OSI ("medieval tactics," "Kafkaesque", "proceeds glacially"). The column also contains factual errors. Specifically, contrary to the assertion in the article,
scientists who are the subject of an inquiry or investigation may see documents related to their cases. PHS ALERT is not a "computerised register of scientists under scrutiny". The ALERT has never been computerised; the information it contains is very closely held and is provided only to the most senior PHS officials, on a strict need-to-know basis, to aid them in making funding, committee appointment, or employment decisions. Most of the names in the ALERT are those of scientists who have been found via a formal investigation to have engaged in misconduct, against whom sanctions have been imposed. The remaining names are those of scientists who have been named as subjects of a formal investigation, following a formal inquiry. Names are removed from the ALERT promptly upon the expiration of the sanctions or upon the conclusion of an investigation with a finding of no misconduct. The ALERT system was established in accordance with the Privacy Act. Details of its operation are described in a Federal Register notice of May 28, 1987 (vol 52, no 102). The ALERT is an entirely appropriate, responsibly operated mechanism for enabling the PHS to carry out its responsibilities to protect the public interest. None of the few lengthy investigations was the result of OSI actions. Some OSI investigations have been prolonged, but this is attributable to such factors as the length of time elapsed since the alleged or suspected misconduct, the fact that the original primary data were not secured by the institution at the time the alleged misconduct was first reported, the existence of litigation involving the principles, the need for extensive fact finding or data analysis to resolve differences of opinion among expert consultants, or the occasional unwillingness of respondents to cooperate with the OSI investigation. In the two years it has been in operation OSI has closed well over 100 cases. Many of these were far more than "simple, usually involving skimpy accusations that required little or no
investigation". WILLIAM F. RAUB,
National Institutes of Health, Bethesda, Maryland 20892, USA
*** This letter has been shown follows.-ED. L.
Acting director to
Mr
Greenberg,
whose
reply
SiR,—Ierred by equating the court’s invalidation of OSI’s procedures with the validity of OSI’s creation. As Dr Raub states, "the issue of whether OSI procedures meet due process requirements was not decided." Space limitations precluded my reporting all details of that part of the ruling. As to OSI’s "medieval tactics", under OSI procedures, the accused is not provided an opportunity to confront the accuser. The accused "may see documents", but not all documents. In the
Baltimore case, for example, forensic conclusions have been stated but the forensic evidence has not been made available to the accused or the press. Computerised or not, the ALERT system is, as Dr Raub’s description attests, a "register of scientists under scrutiny". As the court noted about the ALERT system, in the context of the Abbs investigation, "it would be difficult to argue that the system is delays" in approval of working properly if it did not lead to ...
funding. The Baltimore case came under investigation by OSI’s predecessor in 1987, and is still not resolved. Science and Government Report, 3736 Kanawha Street Northwest, Washington, DC 20015, USA
DANIEL S. GREENBERG
Cutaneous leishmaniasis in Honduras SIR,-Mr Ponce and colleagues (Jan 12,
p 67) report a new of cutaneous leishmaniasis in Honduras. Fiona Jacklin and I have just returned from our student elective in that country, where we undertook a project to establish the epidemiology of cutaneous leishmaniasis in Morozan, a large mountain town in the northern region of Honduras. I thought it would be worth comparing our findings with those of Ponce et al since we looked at ulcerating lesions rather than non-ulcerating lesions. 32 cases were identified by clinical appearance and treated on this basis with a 12-day course of glucantime. Montenegro skin tests were negative in all but 2 patients, in contrast to Ponce and colleagues’ positivity rates of 59% (10 of 17) in non-ulcerated lesions. 24 patients had one ulcer, 5 had two, 2 had three, and 1 had four, most commonly found on the foot:
clinical
variety
By contrast, Ponce et al found non-ulcerated lesions mainly on the face. Ulcerated lesions were present for a much shorter period of time than were the non-ulcerated lesions (1 month vs 2 years), possibly because patients with ulcerated lesions are more worried and hence seek treatment. Children under 5 years were at greatest risk of the ulcerative type of lesion, whereas Ponce et al record only 1 child in this age group with a non-ulcerative lesion. It is noteworthy that this new clinical variety of cutaneous leishmaniasis seems to predominantly affect a different age group, a different part of the body, and for a considerably different duration than do other types. 37 Sandy Lodge Road, Moor Park, Rickmansworth WD3 1 LP, UK
CAROLINE SHAW
Why isolate theatre suites? SIR,-Dr Humphreys and colleagues (Feb 16, p 430) refer to a report that showed very little benefit in the use of a two-trolley system over one trolley in reduction of floor, trolley wheel, and theatre air contamination.’ It is surprising that no mention is made of the geographical location of the theatre in which the work was done, or in the questionnaire to the other 50 hospitals surveyed. Ayliffe et al2 rightly commented that the position of the theatre in relation to the ground floor and other wards would have a noticeable effect on the degree of contamination of trolley wheels and the clothing and footwear of staff. If the theatre suite is situated close to the outside grounds or off a commonly used, soil-contaminated corridor we would expect a higher soil load, and it is then that a transfer area can be of benefit; otherwise the use of such an area
Office of Scientific Integrity SIR,-Dan Greenberg’s Washington Perspective (Feb 2, p 289) contains factual errors and elsewhere inaccurately and unfairly characterises the performance of the Office of Scientific Integrity (OSI) of the National Institutes of Health (NIH). The most significant inaccuracies concern the US District Court ruling in the Western District of Wisconsin in Abbs vs Sullivan et al. The court did not rule that the operations of the OSI are "illegal". The Abbs vs Sullivan litigation did not deal with the creation of the OSI but rather with the US Public Health Service’s 1986 (interim) Policies and Procedures for Dealing with Possible Scientific Misconduct. Nor is it correct to say that the judge "sidestepped as moot" due process issues; the issue of whether OSI procedures meet due process requirements was not decided. However, the issue of whether the University of Wisconsin or Dr Abbs had a liberty or property interest sufficient to merit due process was thoroughly examined and decided in favour of the US Government. Moreover, the judge’s ruling noted that the imposition of Public Health Service (PHS) sanctions less than debarment is not subject to determination of cause after a full hearing-that is, the due process required is at the discretion of the Government. Greenberg’s column contains pejorative, unsubstantiated characterisations of the operations of the OSI ("medieval tactics," "Kafkaesque", "proceeds glacially"). The column also contains factual errors. Specifically, contrary to the assertion in the article,
scientists who are the subject of an inquiry or investigation may see documents related to their cases. PHS ALERT is not a "computerised register of scientists under scrutiny". The ALERT has never been computerised; the information it contains is very closely held and is provided only to the most senior PHS officials, on a strict need-to-know basis, to aid them in making funding, committee appointment, or employment decisions. Most of the names in the ALERT are those of scientists who have been found via a formal investigation to have engaged in misconduct, against whom sanctions have been imposed. The remaining names are those of scientists who have been named as subjects of a formal investigation, following a formal inquiry. Names are removed from the ALERT promptly upon the expiration of the sanctions or upon the conclusion of an investigation with a finding of no misconduct. The ALERT system was established in accordance with the Privacy Act. Details of its operation are described in a Federal Register notice of May 28, 1987 (vol 52, no 102). The ALERT is an entirely appropriate, responsibly operated mechanism for enabling the PHS to carry out its responsibilities to protect the public interest. None of the few lengthy investigations was the result of OSI actions. Some OSI investigations have been prolonged, but this is attributable to such factors as the length of time elapsed since the alleged or suspected misconduct, the fact that the original primary data were not secured by the institution at the time the alleged misconduct was first reported, the existence of litigation involving the principles, the need for extensive fact finding or data analysis to resolve differences of opinion among expert consultants, or the occasional unwillingness of respondents to cooperate with the OSI investigation. In the two years it has been in operation OSI has closed well over 100 cases. Many of these were far more than "simple, usually involving skimpy accusations that required little or no
investigation". WILLIAM F. RAUB,
National Institutes of Health, Bethesda, Maryland 20892, USA
*** This letter has been shown follows.-ED. L.
Acting director to
Mr
Greenberg,
whose
reply
SiR,—Ierred by equating the court’s invalidation of OSI’s procedures with the validity of OSI’s creation. As Dr Raub states, "the issue of whether OSI procedures meet due process requirements was not decided." Space limitations precluded my reporting all details of that part of the ruling. As to OSI’s "medieval tactics", under OSI procedures, the accused is not provided an opportunity to confront the accuser. The accused "may see documents", but not all documents. In the
Baltimore case, for example, forensic conclusions have been stated but the forensic evidence has not been made available to the accused or the press. Computerised or not, the ALERT system is, as Dr Raub’s description attests, a "register of scientists under scrutiny". As the court noted about the ALERT system, in the context of the Abbs investigation, "it would be difficult to argue that the system is delays" in approval of working properly if it did not lead to ...
funding. The Baltimore case came under investigation by OSI’s predecessor in 1987, and is still not resolved. Science and Government Report, 3736 Kanawha Street Northwest, Washington, DC 20015, USA
DANIEL S. GREENBERG
Cutaneous leishmaniasis in Honduras SIR,-Mr Ponce and colleagues (Jan 12,
p 67) report a new of cutaneous leishmaniasis in Honduras. Fiona Jacklin and I have just returned from our student elective in that country, where we undertook a project to establish the epidemiology of cutaneous leishmaniasis in Morozan, a large mountain town in the northern region of Honduras. I thought it would be worth comparing our findings with those of Ponce et al since we looked at ulcerating lesions rather than non-ulcerating lesions. 32 cases were identified by clinical appearance and treated on this basis with a 12-day course of glucantime. Montenegro skin tests were negative in all but 2 patients, in contrast to Ponce and colleagues’ positivity rates of 59% (10 of 17) in non-ulcerated lesions. 24 patients had one ulcer, 5 had two, 2 had three, and 1 had four, most commonly found on the foot:
clinical
variety
By contrast, Ponce et al found non-ulcerated lesions mainly on the face. Ulcerated lesions were present for a much shorter period of time than were the non-ulcerated lesions (1 month vs 2 years), possibly because patients with ulcerated lesions are more worried and hence seek treatment. Children under 5 years were at greatest risk of the ulcerative type of lesion, whereas Ponce et al record only 1 child in this age group with a non-ulcerative lesion. It is noteworthy that this new clinical variety of cutaneous leishmaniasis seems to predominantly affect a different age group, a different part of the body, and for a considerably different duration than do other types. 37 Sandy Lodge Road, Moor Park, Rickmansworth WD3 1 LP, UK
CAROLINE SHAW
Why isolate theatre suites? SIR,-Dr Humphreys and colleagues (Feb 16, p 430) refer to a report that showed very little benefit in the use of a two-trolley system over one trolley in reduction of floor, trolley wheel, and theatre air contamination.’ It is surprising that no mention is made of the geographical location of the theatre in which the work was done, or in the questionnaire to the other 50 hospitals surveyed. Ayliffe et al2 rightly commented that the position of the theatre in relation to the ground floor and other wards would have a noticeable effect on the degree of contamination of trolley wheels and the clothing and footwear of staff. If the theatre suite is situated close to the outside grounds or off a commonly used, soil-contaminated corridor we would expect a higher soil load, and it is then that a transfer area can be of benefit; otherwise the use of such an area
