"The whole aim of practical politics is to keep the populace alarmed
(and hence clamorous to be led to safety) by menacing it with
an endless series of hobgoblins, most of them imaginary."
H. L. Mencken (1922)
No animals or ethicists were harmed during this work,
nor IRBs consulted.
Is it just the usual bureaucratic and governmental waste and incompetence, or is it social engineering? Of course, it could be both.
Do we really need Institutional Review Boards (IRB) or Research Ethics Boards (REB) for research in the Social Sciences and Humanities? I don't think the case has been shown, and it will not be as long as the focus is on compliance rather than effectiveness.
Several years ago I suffered with an Honors student, waiting five months (plus) to get permission to administer a commonly used self-efficacy questionnaire to college students. This student barely finished in time, and decided not to pursue a research career in Psychology, a decision one now sees with some regularity.
I decided to examine the research ethics industry more closely. This page compiles some of what I've found, and frankly it isn't pretty. This enterprise has unnecessarily stifled social sciences and humanities research for over 30 years, with no evidence of need, no evidence of benefit, and no concern for the lack of evidence. In fact, there is better evidence for the waste and out-right abuse associated with IRB/REB activity.
Some of these documents require the free Adobe Acrobat Reader,
or the free Powerpoint viewer, Windows, and Mac
Some of the early thoughts have been published in some pieces in the American Psychological Society Observer:
Of course, letters and essays such as these are read by researchers, and not by regulators and ethicists, neither of whom care a bit for data. It is difficult to get contrarian ideas into a public forum, as most formats are dominated by "This is the law," and "This is 'the right thing to do'" -- no need for evidence with those pulpits. Such reasons seem unethical, to me, and certainly are not scientific.
- September, 2001, Waste(1)
- October, 2001, Waste(2)
- October, 2002, ABCs
- February, 2003, Dummies
- July, 2003, Accreditation is more waste?
- October, 2003, Why the 'overkill' by local ethics boards?NOTE: I have had the pleasure of regular companions in expressing some of these opinions, in the persons of John Furedy, Clive Seligman, and Steve Lupker. JOHN FUREDY has been a critic longer than I have, and he has a research ethics page of his own with some of his early writings. (Of course none of them bear any responsibility for what I say here.)
1. In the spring of 2006, a symposium was held at Northwestern University by the Law Schools of Northwestern University and the University of Chicago, entitled "Censorship and IRBs". The papers from that have now been published and are available on-line at Northwestern University Law Review, 2007, v. 101(2).
2. Symposium at the American Psychological Association Convention, San Francisco, August 19, 2007: "Human Subject Protection, Academic Freedom and the First Amendment: Can't We Have It All?" This symposium involved papers by Michael Birnbaum, Richard O'Brien, and John J. Furedy. Their abstracts can be downloaded here, and the authors contacted for more.
A symposium at the American Psychological Association convention (July 29, 2004, Honolulu),
"Protecting Science and Academic Freedom from Institutional Review Boards".
- KURT SALZINGER (Hofstra): Chair & Discussant (Can we just eliminate IRBs and license researchers like we do therapists?)
- HAROLD TAKOOSHIAN (Fordham): "An impressive solution to a nonproblem" (Can we implement a 'Bill of Rights' for researchers?)
- JOHN H. MUELLER (Calgary): "Best practices: What perspective, what evidence?" (Why aren't we collecting evidence re effectiveness?)
- RICHARD M. O'BRIEN (Hofstra): "Galileo 1 - Pope Urban 0: How we learned to limit our IRB" (Can we bring IRB decisions into Collective Bargaining Agreements as grievable?)
- JOHN J. FUREDY (Toronto): "Taxonomic chaos in the Canadian bioethics industry: Apres Moi la Deluge" (Why are IRBs confusing epistemology with 'ethics'?)
Several of the symposium articles are reprinted in the Journal of Social Distress and Homelessness, 2006, 15 (#1) (or obtainable by clicking an e-mail to the author above).
Some other recent efforts to offset the compliance obsession:
- A chapter (2004) detailing how research ethics may become the tool of choice in harassing faculty, by those on campus and off campus. Is there such a thing as liability insurance for researchers, they sure don't get protected by any of the ethics rigmarole.
- I was a participant at a human subjects workshop at the University of Georgia (July 29, 2003); mine was indeed a contrarian viewpoint in a sea of compliance how-tos. Although the workshop was supposed to be about Social and Behavioral Sciences research ethics, the federal regulators presented one medical issue after another, par for the course. My subjects are not "patients," and there are many other reasons that the imposition of the medical research model creates serious problems in social and behavioral research. (The Powerpoint file is here)
- A recent research ethics essay was at SAFS (June 12, 2003). Sometimes one preaches to the converted, but it's fun - watch out for the elephants! Sadly the ethics industry has no sense of humor, essentially like any collection of self-righteous zealots or missionaries, that is to say, the entire politically correct movement. "Evangelical" seems to be an antonym for humor, and it is an adjective that applies to the mindless extreme of any cause (not just certain Christian groups).
It is encouraging that others are noticing some of the same things.
- THE CREEPS:
The never-ending expansion has been noted in a some recent articles. (It is much like the incessant expansion of any bureaucracy, e.g., the American Disabilities Act.)
- University of Illinois white paper, by C. GUNSALUS et al., with a more recent editorial in Science.
- KEVIN HAGGERTY, an acquaintance in the Sociology Department at the University of Alberta, also has a nice recent article, "Ethics Creep," in Qualitative Sociology, Vol. 27, No. 4, Winter 2004. 391-414. I may post it here in the future, but for now request it directly from him.
- Kevin Haggerty also has another article on-line, addressing the disparity in how academic scholars and journalists are treated.
- PHILIP HAMBURGER has an excellent effort at possible censorship challenges to the IRB industry, at The New Censorship: Institutional Review Boards
- TED PALYS and colleagues at Simon Fraser University have been coping with issues around requests to divulge identity, after having been obliged to assure participants of their anonymity, which you can read about here.
- MAUREEN FITZGERALD has been studying, among other things, the transparency of ethics committee operations in Australia and elsewhere, and her efforts are avaiable at The Ethics Project.
- ZACH SCHRAG has started a blog on Institutional Review Boards, updated regularly, excellent analysis and commentary.
- Ethnologists have been organizing commentary as well, as in a special issue of the American Ethnologist, Vol. 33, No. 4 (November 2006), from the American Ethnological Society.
- The December, 2007, issue of Law and Society Review contains a Presidential address by Malcolm Feeley, with commentaries by others.
The research ethics industry habitually refers to historical (medical) problem cases as justifying present-day expansion of REBs (IRBs). I find little merit in these claims, it's just a disingenuous scare tactic. Current IRB/REB procedures would not have prevented these historical abuses, so they are logically irrelevant to present practices. Interestingly most of the classic horror stories involve research by government agencies, yet we have a government agency (e.g., OHRP) lecturing us on ethics.It has long been acknowledged that federal funds can corrupt scholarship, for example: "The prospect of domination of the nation's scholars by Federal employment, project allocations, and the power of money is ever present -- and is gravely to be regarded", Dwight Eisenhower, Presidential Farewell Address, Jan. 17, 1961. Universities have been bought by federal grant agencies, and they seem quite happy to put up with IRBs to stay bought.
One wonders just how much impact "public consultations" have, but you have to try. Canada is in the process of revising some of its policies, and here are some commentaries re social science research from SAFS:
- Some commentary on research ethics accreditation plans in Canada (2002). Another solution looking for a problem -- Bureaucracy 101, create more bureaucracy to solve a problem created by bureaucracy.
- The Social Science and Humanities Working Committee (Canada) has solicited input in regard to possible revisions in Canada's TCPS, some comments available here (Sept. 15, 2003). It seems next to impossible to get across that medical clinical trials are a very poor model for research in the Social Sciences and Humanities.
- Corroborating the conclusion that consultations have no impact, the fall of 2007 finds at least two more requests for commentaries on proposals that show no impact of previous consultations:
BIGFOOT? In the specific case of social and behavioral sciences research, in spite of several inquires in recent years, I have as yet to find that subject who was harmed in such research. In fact, there is more concrete evidence presented in support of Sasquatch than for a harmed subject in social and behavioral science research!
Once upon a time life was tougher, so were we! It's amazing, we're all descended from people who coped with REAL problems, e.g., the Bubonic plague, even historical epochs of global warming (and cooling). However, today so many people can't even handle being "offended" or "insulted." Shouldn't we be a bit concerned about the future of the species when we can't handle even minor annoyances?Possibly the saddest obituary ever written?
Unfortunately, after 30 years of IRB/REB "development" it may be especially difficult to make changes, as explained here.
Further discussion of related issues can be found at Zero Tolerance Disorder. (working draft)
It is estimated (JAMA, 2000) that there are 120,000 doctor-caused deaths in the USA every year. (Actually this is perhaps low, as it is only incidents in hospitals where reporting is required, so it does not include out-patient incidents. This statistic is sometimes disingenuously labeled "Iatrogenic Disease," but it is hardly a 'disease' as most of us understand that term!)
The research sector, even in medical research, looks quite capable in comparison, eh? Further, this statistic lends itself to some other interesting relative-risk comparisons. Everyday risk is something about which too many people have absolutely no understanding. This may be the reasonable consequence of a concerted effort to convince people that a zero-risk world is achievable.