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Section 3 (Chapters 3.1 & 3.5), Glossary and Revisions to Section 5 National Statement on Ethical Conduct in Human Research, 2007 submission

ID: 
8
Personal Details
First Name: 
Max
Last Name: 
Travers
Specific Comments
Comments: 
1. Introduction to Section 3

Principles

 

1.  In commenting on these changes, I am guided by a belief in the value of

      free expression and inquiry.   It is important to ensure that ethical

      guidelines, and how the ethics system operates, strikes the right

      balance.

 

2.  I am aware from my own work as a supervisor and researcher that the

      current system can make conducting research difficult.   Here are three

      examples:

 

  • A doctoral student who wanted to conduct focus groups with citizens about environmental issues was advised that this involved too great a risk.  The student withdrew from the doctoral program.

 

  • An Honours student from an Indigenous community, who had the support of the community, was effectively blocked from pursuing a project based on interviewing Indigenous elders (there were three request for revisions).  The student withdrew and eventually conducted a project based on public documents.

 

  • Students and researchers seeking permission to observe public legal hearings were asked to make a case that this is public space.

 

 

2. Chapter 3.1

3.1   Last paragraph.   I suggest adding a sentence:

        “Research may involve emotional and other risks to both participant

         and researcher.  Some projects will not involve emotional risks”. 

 

         The aim of this amendment is to make it more difficult for ethics

         committees to assume that there are emotional risks in every project.

 

3.1.5  I would change this to:

“In their assessment of research quality, reviewers must recognize that thematic and other forms of generalizability may be more relevant than statistical generalizability.   There are different understandings in quantitative and qualitative research”.

 

The aim of this amendment is to make it more difficult for ethics

            committees to apply criteria on generalizability from the

            quantitative tradition.

 

3.1.25   This refers researchers to Chapters 2.2 and 2.3 for guidance on

               waiver of consent.  Although we are not asked to comment on

               these sections, in my view ethics committees need clearer

               guidance.  Ideally, I would like public legal hearings recognized as

               public space in the National Statement. 

 

3.1.31    I would suggest changing the term “potentially significant” to

                “potentially harmful”.

 

              The aim of this amendment is to maintain consistency with the

               principles of ethics review.   I am not sure that ethics committees

               will understand the term “potentially significant”.

 

3.1.25-37   I would like an additional clause stating that oral consent is

         permitted when appropriate (for example, in low risk research

         or when interviewing sensitive groups).

 

        The aim of this amendment is to make it more difficult for ethics

                     committees to require written consent for every project.

 

3.1.42   I like the first sentence.  This is an example of how the National

               Statement can give clearer direction to ethics committees.

 

3.1.45   If data is public, researchers should be allowed to use the data. 

               This seems an important principle.   Otherwise, we could not

               use newspaper reports or books without the author’s permission.

               See my comments above on the need for balance in ethics

               review, allowing free expression and inquiry.

 

3.1.47    There should be a waiver of consent for using public data. 

 

3.1.67-68   I would suggest making it clear that this section only applies to

                      health research, or redrafting.   There is no need for a

                      communication plan in social science research.  Nor should

                      participants necessarily be given the option of seeing the

                      “results”.   This would make doing research difficult. The key

                      issue should be whether there is a risk of harm, weighed

                      against the benefits to society of the project. 

General Comments
Comments: 

Consultation on proposed changes to the National Statement on Ethical Conduct in Human Research

 

Comments by Dr. Max Travers, School of Social Sciences, University of Tasmania  (27th November 2016)

 

 

Principles

 

1.  In commenting on these changes, I am guided by a belief in the value of

      free expression and inquiry.   It is important to ensure that ethical

      guidelines, and how the ethics system operates, strikes the right

      balance.

 

2.  I am aware from my own work as a supervisor and researcher that the

      current system can make conducting research difficult.   Here are three

      examples:

 

  • A doctoral student who wanted to conduct focus groups with citizens about environmental issues was advised that this involved too great a risk.  The student withdrew from the doctoral program.

 

  • An Honours student from an Indigenous community, who had the support of the community, was effectively blocked from pursuing a project based on interviewing Indigenous elders (there were three requests for revisions).  The student withdrew and eventually conducted a project based on public documents.

 

  • Students and researchers seeking permission to observe public legal hearings were asked to make a case that this is public space.

 

 

Revisions to Section 3

 

3.1   Last paragraph.   I suggest adding a sentence:

        “Research may involve emotional and other risks to both participant

         and researcher.  Some projects will not involve emotional risks”. 

 

         The aim of this amendment is to make it more difficult for ethics

         committees to assume that there are emotional risks in every project.

 

3.1.5  I would change this to:

“In their assessment of research quality, reviewers must recognize that thematic and other forms of generalizability may be more relevant than statistical generalizability.   There are different understandings in quantitative and qualitative research”.

 

The aim of this amendment is to make it more difficult for ethics

            committees to apply criteria on generalizability from the

            quantitative tradition.

 

3.1.25   This refers researchers to Chapters 2.2 and 2.3 for guidance on

               waiver of consent.  Although we are not asked to comment on

               these sections, in my view ethics committees need clearer

               guidance.  Ideally, I would like public legal hearings recognized as

               public space in the National Statement. 

 

3.1.31    I would suggest changing the term “potentially significant” to

                “potentially harmful”.

 

              The aim of this amendment is to maintain consistency with the

               principles of ethics review.   I am not sure that ethics committees

               will understand the term “potentially significant”.

 

3.1.25-37   I would like an additional clause stating that oral consent is

         permitted when appropriate (for example, in low risk research

         or when interviewing sensitive groups).

 

        The aim of this amendment is to make it more difficult for ethics

                     committees to require written consent for every project.

 

3.1.42   I like the first sentence.  This is an example of how the National

               Statement can give clearer direction to ethics committees.

 

3.1.45   If data is public, researchers should be allowed to use the data. 

               This seems an important principle.   Otherwise, we could not

               use newspaper reports or books without the author’s permission.

               See my comments above on the need for balance in ethics

               review, allowing free expression and inquiry.

 

3.1.47    There should be a waiver of consent for using public data. 

 

3.1.67-68   I would suggest making it clear that this section only applies to

                      health research, or redrafting.   There is no need for a

                      communication plan in social science research.  Nor should

                      participants necessarily be given the option of seeing the

                      “results”.   This would make doing research difficult. The key

                      issue should be whether there is a risk of harm, weighed

                      against the benefits to society of the project. 

Supporting attachments

Page reviewed: 10 July, 2018