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Review of the Australian Code for the Responsible Conduct of Research Submission

Personal Details
This submission reflects the views of
Organisation Name: 
Health Consumers Alliance SA
Specific comments
Specific comments: 
Preamble in Code

In the recently published NHMRC document 'Statement on Consumer and Community Involvement in Health and Medical Research (September 2016), the purpose section of the Statement says: 'NHMRC recognises that involving consumers and community members can add value to health and medical research and they have a right and responsibiity to do so. The Australian Code for the Responsible Conduct of Research (2007), the primary guidance for institutions and researchers in responsible research practice states:

Appropriate consumer involovement in research should be encouraged and facilitated by research institutions and researchers.

In additon, NHMRC encourages researchers to consider the benefits of actively involving consumers in their proposed research, when they apply for research funding.

HCA is concerned this information, nor an associated relevant principle, is clearly not included in the current (2017) draft. 

Nor are we reassured by the inclusion that says 'humans and other aniimals will be respected, along with the evironment'.  We consider it quite a risk to publish this statement.

We strongly advise you to include a principle regarding co-research or comprehensive/appropriate consumer involvement. This is a human and moral right, and it is clearly aligned with the growing empirical and pracitice evidence. There is an example demonstrating this on the HCA webiste: www.hcasa.asn.au The framework for consumer and community engagment for the South Australian Health and Medical Research Institute (SAHMRI). Cancer Australia also has a related doucument on their website. www.canceraustralia.gov.au


Principles in Code

No comment

Specific consultation questions
Question 1: Do you like the new approach to the Code, namely the principles-based document being supported by several guides that provide advice on implementation?: 
Yes it is an excellent approach.
Question 2:The draft Code is intended to be used by all research disciplines. Do the principles adequately capture the expectations for responsible research across all research disciplines?: 
No the principles lack inclusion of the: 'Appropriate consumer involvement in research should be encouraged and facilitated by research institutions and researchers'.
Question 3: The draft Guide refers to breaches of the Code rather than providing a definition of research misconduct, and states that institutions can decide whether or not to use the term research misconduct in their own processes.: 
Referring to breaches of the code rather than providing a definition of research misconduct is an excellent approach. Managing misconduct should fit within the governance of institutions.
Question 4: Do you think the process described for investigating and managing potential breaches of the Code is clearly described and practical?: 
Question 5: The Code Review Committee and working group are considering what additional resources should be developed to support implementation of the Code and Guide.: 
Not sure
Question 7: Please comment on which three topics you would nominate as being the highest priority and why.: 
Consumer and community engagement

Page reviewed: 17 September, 2018