50 / 106
The OMB with input from members of the Board of Directors has developed an initial proposal for
procedures (see attachment 1). While this approach seems reasonable, there are still several
feedback loops in place to ensure that all appropriate considerations have been taken into account
and to avert potential challenges. In the end, there are more steps involved to ensure that a
modification is substantiated and acceptable than the consideration and review of a new method for
OMA.
New method applications simply need to be submitted with manuscript by a prescribed deadline.
AOAC Research Institute issues a Call for Experts for an expert review panel. During a meeting, an
expert review panel reviews the method and renders a decision on whether or not to adopt a
method. In the past 12 years of my tenure at AOAC, I have yet to hear of an incidence where there
has been a challenge to an approval of a new First Action method.
RECOMMENDATION:
Therefore, it is my recommendation as Senior Director for AOAC Standards Development and for the
AOAC Research Institute to cease modifying current
Official Methods of Analysis
(First Action or Final
Action) with only the exception being for well‐defined editorial changes, and treat all method
submissions as new methods regardless of whether or not they are modifications to an existing
OMA. This approach makes all method submissions eligible for a new method number and review
by an Expert Review Panel. The Expert Review Panel can decide if an older OMA should be
recommended for repeal as a result of adopting any new method.
This approach reduces or eliminates the need to:
1.
Delineate major and minor categories
2.
Decipher examples into the categories based on a wide array of possible method changes
3.
Track changes to methods
4.
Reconsider how to handle method modifications, method extensions, and matrix extensions
5.
Have separate processes for methods approved using SMPRs or administered through the
Research Institute.
Furthermore, there would only be well‐defined editorial changes to a method and a new method.
Also, this approach keeps ERPs and OMB in their current role.
OMB MEETING MATERIALS - October 1, 2015
37