We are writing in response to a proposed rule announced by the Environmental Protection Agency (EPA) in a 24 April 2018 press release (1). The release reads, “The rule will ensure that the regulatory science underlying Agency actions is fully transparent, and that underlying scientific information is publicly available in a manner sufficient for independent validation.”
Data sharing is a feature that contributes to the robustness of published scientific results. Many peer-reviewed scientific journals have recently adopted policies that support data sharing, consistent with the Transparency and Openness Promotion (TOP) standards. These standards, however, recognize the array of workflows across scientific fields and make the case for data sharing at different levels of stringency; in not every case can all data be fully shared. Exceptional circumstances, where data cannot be shared openly with all, include data sets featuring personal identifiers.