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Learn about proper record-keeping in laboratory notebooks, electronic record-keeping, ownership rights, public access, and more. Understand research data guidelines and requirements to maintain data integrity.
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Scientific Record Keeping Alan L. Goldin, M.D./Ph.D.
Laboratory Notebooks • Bound, serially numbered pages • All entries should be dated • Permanent ink • Table of contents • Include the actual data, such as photographs, negatives, autoradiograms and printouts
Data in Laboratory Notebooks • Original data should be included • Photographs, negatives and similar can be glued or taped • Other materials can be inserted in plastic sleeves (including CD or DVD) • Oversize material and magnetic media should be stored, with the location and coding scheme included in the lab book
Laboratory Notebook Requirements Can be More Detailed • Data book paper should be acid-free • Bindings should be sewn or glued • Plastic comb, wire spiral, or ring binders are considered unacceptable • Data books may be inventoried • Master data book log • This policy applies in industry
Policies in Industry • Only bound laboratory notebooks are acceptable • Entries must be countersigned weekly or more often • The rules are stricter because the notebooks may be used as evidence to gain patent protection
Electronic Record Keeping • ELN – Electronic Laboratory Notebook • Database software • Generic electronic notebooks • Scientific electronic notebooks • CENSA – Collaborative Electronic Notebook Systems Association
How long to keep notebooks? • NIH policy mandates 3 years after the end of the project (grant funding period) • FDA policy mandates 10 years after use • Patent policy mandates 23 years after issue of the patent
How long to keep notebooks? • The organization with the longest policy has priority • State law usually overrides federal laws • Virginia mandates that data by state agencies must be retained for 5 years • Investigators in Virginia at state-supported universities must follow that policy
Who owns the notebooks & data? • When NIH awards a research grant to a university, any and all data collected as part of that funded project are owned by the grantee institution • Data books of all investigators (PI, postdocs, grad students, technicians) are the property of the institution
Who owns the notebooks and data? • The principal investigator is the steward • If the PI resigns or moves to another institution: • Equipment and all data belong to the initial institution • Permission can be obtained to transfer the award, equipment and data
Public Access to Data • The Office of Management and Budget (OMB) revised the regulations regarding public access to experimental data in 1999 • Circular A-110 included the revisions • The public can obtain access to experimental data through the Freedom of Information Act (FOIA)
Applicability • Data produced with Federal support that are cited publicly and officially • Data collected by institutions of higher education, hospitals, and non-profit institutions • Does not apply to commercial organizations • Does not apply to state and local governments • Applies to new and competing awards made after the effective date of the amendment (11/8/1999)
Research Data • Recorded, factual material commonly accepted in the scientific community as necessary to validate research findings • Published • Peer-reviewed scientific or technical journal • Cited by a Federal agency publicly and officially
Research Data Do Not Include: • Preliminary analyses • Drafts of papers • Plans for future research • Peer reviews • Physical objects (samples, tapes) • Trade secrets or commercial information
FOIA Request Must Include: • Specific regulation or order citing the data • Publication cited • Grant number • Description of the data being sought • A statement that the data are being requested under the amendment to Circular A-110
What happens if the PI has moved? • Research grants are award to institutions, not individuals • The FOIA office will send the request to the institution • Both the FOIA office and the institution will try to locate the PI and fulfill the request for data
What happens if the PI refuses to comply with the request? • This would be viewed as a material failure to comply with the terms and conditions of the award • NIH would initiate appropriate enforcement action • This could include withholding future support to the institution
What if the data are in an abstract cited in a Federal regulation? • If the abstract is based on preliminary analyses, then the data would be excluded • If the abstract is not based on preliminary analyses and is cited by a Federal agency in a regulation, then the data may be accessible
Additional Sources of Information • Responsible Conduct of Research Education Consortium (RCREC) Web Site • Office of Management & Budget Circular A-100 (section 36) • NIH Working Group Report on Research Tools