Public comment period · §3
Draft print and archival format for Institute documents — disposition
The disposition of every submission and the amendments that resulted.
§3Disposition and amendments
§3.1Disposition table
Table 1. Every submission with its disposition. Each row links to the submission in full.
| Reference | Respondent | Point raised | Disposition |
|---|---|---|---|
| DRAFT-PRINT-AND-AR/001 | Dr Quentin Gwynne-Sarpong | A declared interest is published without being tested | Accepted |
| DRAFT-PRINT-AND-AR/002 | Dr Vasilisa Immelmann | There is no route to challenge a disposition | Accepted |
| DRAFT-PRINT-AND-AR/003 | Vittoria Ylönen | A declaration is made on appointment and never refreshed | Accepted in part |
| DRAFT-PRINT-AND-AR/004 | Dr Evander Ashworth-Danquah | Assessment committee meetings are held in private | Noted, no amendment |
| DRAFT-PRINT-AND-AR/005 | Kolawole Oppenheimer-Ade | Anonymous submissions should be accepted where the respondent risks employment consequences | Not accepted |
| DRAFT-PRINT-AND-AR/006 | Ms Rhiannon Okoye-Vandergraaf | A four-week window is too short for a respondent without institutional support | Accepted in part |
| DRAFT-PRINT-AND-AR/007 | Dr Odalys Thorsby-Nakamura | Absence of evidence is presented in a form a reader will take as negative evidence | Accepted |
| DRAFT-PRINT-AND-AR/008 | Georgiana Zimmerthal | No term limit applies to membership of the assessment committee | Accepted |
| DRAFT-PRINT-AND-AR/009 | Dr Jozef Brandvold-Achterberg | Disagreement within the assessment committee is not visible | Accepted |
| DRAFT-PRINT-AND-AR/010 | Dr Georgiana Mountstephen | Funding should not be accepted from any party the Institute assesses | Accepted in part |
| DRAFT-PRINT-AND-AR/011 | Professor Bartolomeu Nkosi-Lindegaard | A party criticised in an assessment should have a right of reply | Accepted in part |
| DRAFT-PRINT-AND-AR/012 | Dr Fitzwilliam Danquah-Öberg | Quantitative claims are reproduced without the method that produced them | Accepted |
| DRAFT-PRINT-AND-AR/013 | Kamila Ubertini | The position of a contributor who withdraws consent is not stated | Accepted |
| DRAFT-PRINT-AND-AR/014 | Dr Rurik Haverkamp-Diallo | The materiality threshold for a declarable holding is set too high | Accepted in part |
| DRAFT-PRINT-AND-AR/015 | Ivo Mountstephen | A reader who acted on a document is not told when it is corrected | Accepted |
| DRAFT-PRINT-AND-AR/016 | Quentin Whitmarsh-Obi | References should carry a persistent identifier for every cited source | Accepted in part |
| DRAFT-PRINT-AND-AR/017 | Kolawole Jankowiak-Osei | The policy does not say who may make a submission | Accepted |
| DRAFT-PRINT-AND-AR/018 | Anselm Mountstephen | The policy does not say what happens to a document the Institute is asked to remove | Accepted |
| 18 submissions in total. | |||
§3.2Summary by disposition
Table 2. Counts by disposition, with the meaning of each.
| Disposition | Count | Meaning |
|---|---|---|
| Accepted | 10 | The submission is accepted and the draft is amended as proposed. The amendment is recorded in the amendment log of the document it changed and is traceable to the numbered submission. |
| Accepted in part | 6 | Part of the submission is accepted and part is not. The secretariat response states which part is which and on what ground the remainder was declined. |
| Noted, no amendment | 1 | The submission raises a point the Institute accepts but that does not require a change to the draft, most often because the draft already states it elsewhere. The location is given in the response. |
| Not accepted | 1 | The submission is not accepted. The secretariat response gives the reason. A submission that is not accepted remains published in full; the Institute does not remove a submission because it disagrees with it. |
§3.3Resulting amendments
- A declared interest is published without being tested — arising from DRAFT-PRINT-AND-AR/001. The policy now states that declarations are published as made, that the Institute does not investigate them, and that where a declaration appears incomplete the respondent is asked to complete it before publication. That the Institute does not verify is now…
- There is no route to challenge a disposition — arising from DRAFT-PRINT-AND-AR/002. A disposition may now be referred for review to a member of the assessment committee who did not author the response, once per submission, with the referral and its outcome published alongside the original disposition whether or not it changes.
- A declaration is made on appointment and never refreshed — arising from DRAFT-PRINT-AND-AR/003. Interests are re-declared annually and the date of last declaration is published against each entry. Declaration against each document was considered and would produce a volume of unchanged text in which a change would be harder to see.
- A four-week window is too short for a respondent without institutional support — arising from DRAFT-PRINT-AND-AR/006. The minimum window is now six weeks for a document of general application and four for a document-specific draft. A respondent who asks for more time before a window closes is given it, and that is now stated in the policy.
- Absence of evidence is presented in a form a reader will take as negative evidence — arising from DRAFT-PRINT-AND-AR/007. A standing formulation has been adopted and is applied wherever an evidence gap is recorded, distinguishing an outcome assessed and not demonstrated from an outcome not assessed. The formulation is identical at every occurrence so that it can be recognised at…
- No term limit applies to membership of the assessment committee — arising from DRAFT-PRINT-AND-AR/008. Members are appointed for a four-year term renewable once. Appointment and expiry dates are published in the register of members.
- Disagreement within the assessment committee is not visible — arising from DRAFT-PRINT-AND-AR/009. A ratification record is now published with every document stating whether the assessment was unanimous, and a member may record a dissenting statement which is published with the document rather than in minutes.
- Funding should not be accepted from any party the Institute assesses — arising from DRAFT-PRINT-AND-AR/010. 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…
- A party criticised in an assessment should have a right of reply — arising from DRAFT-PRINT-AND-AR/011. A standing correction route is now published, corrections of fact are assessed and applied at any time with the change recorded in the amendment log, and a submission of substance received outside a window is held and published in the next comment period on…
- Quantitative claims are reproduced without the method that produced them — arising from DRAFT-PRINT-AND-AR/012. Every quantitative claim now carries the determination that produced it at the point of use, and figures obtained by non-comparable methods are no longer presented in the same row or sentence.
- The position of a contributor who withdraws consent is not stated — arising from DRAFT-PRINT-AND-AR/013. 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…
- The materiality threshold for a declarable holding is set too high — arising from DRAFT-PRINT-AND-AR/014. 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.
- A reader who acted on a document is not told when it is corrected — arising from DRAFT-PRINT-AND-AR/015. A corrected passage now carries an inline notice for twelve months from the date of correction, naming the log entry, in addition to the entry itself.
- References should carry a persistent identifier for every cited source — arising from DRAFT-PRINT-AND-AR/016. Every reference without a persistent identifier now carries an explicit statement that the identifier is not held by the Institute, so that its absence is a recorded fact rather than an apparent oversight.
- The policy does not say who may make a submission — arising from DRAFT-PRINT-AND-AR/017. The policy now states that any person may make a submission, that no affiliation is required, and that the declaration requirement applies identically to every respondent.
- The policy does not say what happens to a document the Institute is asked to remove — arising from DRAFT-PRINT-AND-AR/018. 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…
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.
Compound Evidence Institute · CEI-CP-037/3 · https://compoundevidence.com/comment-periods/draft-print-and-archival-format/disposition/ · retrieved 30 July 2026