Research Ethics Boards (REBs) Request For Comment From Members

January 2008

Dear SAFS Members:

As you may be aware, Steve Lupker and I have written before that changes in the research ethics review system have consistently increased the burdens on individual researchers, in the social sciences and humanities (SSH) in particular, and on local university administrations, with no documented benefit in terms of the protection of research participants.

This summer and fall we've seen several new proposals involving further expansion of the research ethics industry in Canada. For example, one of these proposals was entitled "Continuing Ethics Review," which called for a new campus committee to monitor the progress of your research after the local Research Ethics Board (REB) has approved it. In addition to the extra cost and complexity that such a monitoring committee would entail (without commensurate benefit), one feature of this proposal was to allow this committee access to "documents generated by the study." As ill-defined as this is, and as expansionistic as REBs have been, this seemed to us to be opening the door to a local review of your research before it could be submitted to a peer-reviewed journal. This would provide the local authorities with an excellent opportunity to censor locally unpopular findings at a very early point in their evolution. Our commentary on this proposal can be accessed on the SAFS web site under "Issues".

Our most recent commentary was a response to a proposal known as "Moving Ahead," which also can be accessed under "Issues" on the SAFS web site The Moving Ahead proposal argues for the creation of an über-agency to preside over the several existing agencies. In essence, it would be the agency that provides the necessary accreditation to the lower-level agencies including local REBs. The rationale for establishing this agency is that the present situation involves a conflict of interest, with the federal granting agencies doling out monies and at the same time serving as ethics monitors under the Tri-Council Policy Statement. Ironically, this über-agency is projected to itself operate in a conflict of interest situation re its accreditation and education functions.

It seemed most unlikely that more bureaucracy will yield greater efficiency and, hence, we suggested that the proposal for the über-agency should be rejected for that reason alone. We expect, of course, that these arguments will fall on deaf ears. What this proposal also did, however, was to raise the question about the statutory authority for the proposed expansion (and, quite likely, the statutory authority for many of the ethics bureaucracy structures that are already in place).

That is, while noting that the goals of the über-agency would be achieved more readily with the statutory authority of legislation, nonetheless, the Moving Ahead proposal explicitly recommended against seeking such authority. The implication seems to be that because considerable control has been handed to the ethics bureaucracy without statutory authority, it would be risky to go back and ask for the legal authority to do what is already being done.

We are not the only ones concerned about the continued expansion of the ethics bureaucracy in general, as links on the SAFS web site will attest. However, the purpose of this letter is to note our concern about the lack of statutory authority for this über-agency. We are asking for your input with regard to three questions.

(1) Overall, how can researchers be more effective in getting the message through to the appropriate office holders that the ethics system in Canada is in trouble, and what is the best venue for communicating this?

(2) Should we pursue the question of statutory authorization for the new agency? The argument for doing so is that it may be a way to curtail the unwarranted expansion that has characterized the research ethics enterprise. The argument for not doing so is that more government involvement could well be worse than the disease.

(3) If you think this question of authorization should be pursued with the present government, who would you think we should approach, and how? Should such pursuit be officially associated with SAFS or be done unofficially?

We welcome your thoughts on any of these three questions, or the research ethics enterprises in general, by e-mail to me (, or Steve (, or Clive (