FAQs: Conflict or Bias (COB)

Conflict or Bias means a potential, actual, or an appearance of a conflict and/or bias between the obligations of a person as a Program employee or contractor, and a personal or corporate interest.

This document is a Statement of Policy by NIOSH about potential or actual conflicts or biases (COBs) of those persons or entities carrying out responsibilities for the NIOSH Dose Reconstruction Program.

Disclosure and exclusion of COB ensures and maximizes the quality, objectivity, utility and integrity of all scientific information disseminated by the Program. Achieving the highest level of scientific information quality is a core value of the President’s Office of Management and Budget and the U.S. Department of Health and Human Services.

Thus, it is crucial for Program integrity that each employee and corporate entity performing any key Program function or Program support function disclose fully all past, current or planned future employment-related relationships, financial relationships, familial relationships, or supervisory or subordinate work relationships that could pose a COB.

The COB Policy applies to all persons and corporate entities disseminating scientific information as a part of the NIOSH Dose Reconstruction Program.

NIOSH’s COB Policy Statement is posted and will be updated on the Dose Reconstruction and About DCAS pages of our website.

Please Note: NIOSH reserves the right to amend this COB Policy at any time to take account of changed facts and circumstances.

The COB Disclosure Form is a form that must be filled out by each person or entity carrying out responsibilities for the NIOSH Dose Reconstruction Program. The form contains a series of questions designed to assist covered entities in determining whether a COB may exist arising from a past, current or planned employment-related, financial, familial and/or a supervisory relationship.

COB Disclosure Statements are located on the Conflict or Bias Policy and Disclosure Statements page on our website.

The existence of a COB excludes the individual or corporate entity from performing a key program function associated with a site where a conflict or bias exists. Persons or entities excluded from performing a key program function may perform a program support function after disclosing the conflict or bias.

This document summarizes the legal requirements regarding conflicts of interest which apply to NIOSH employees and members of the Advisory Board on Radiation and Worker Health as Federal employees; it also outlines NIOSH’s Appearance of Bias Policy regarding participation in activities related to the Energy Employees Occupational Illness Compensation Program Act (EEOICPA).

A copy of this document is located on the Advisory Board Procedures page of our website.

Note: NIOSH is in the process of putting this new policy into operation.

The DCAS conflict of interest point of contact and the NIOSH Conflict or Bias Officer are available to answer questions regarding the NIOSH COB Policy and its implementation.

• DCAS Conflict of Interest Point of Contact (COI POC)

  Grady Calhoun
  Email: dcas@cdc.gov
  Phone: 513-533-6800 or toll-free at 1-877-222-7570.

• NIOSH Conflict or Bias Officer

  The NIOSH COB Officer reports directly to the NIOSH Director. He is responsible for ensuring that any key Program function document disseminated by NIOSH conforms substantively and procedurally to all the provisions contained in this COB Policy Statement. In addition, the COB Officer manages the process to ensure that all key Program function documents conform to the NIOSH COB Policy Statement. For example, the COB Officer will review all disclosures; investigate and resolve complaints about failure to disclose; may examine key Program documents for proper attribution; and examine the roles of the document owner, site, and subject experts in key Program documents.

  Frank Hearl
  Email: COBOfficer@cdc.gov
  Phone: toll-free at 1-877-222-7570