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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: 
The Australian Society for Medical Research
Specific comments
Specific comments: 
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?: 
We support the transition away from a rules-based code to a less prescriptive principles-based code, as presented in the public consultation draft. This will enable greater self-regulation at the institutional level and will provide flexibility within the Code to respond to unanticipated or unforeseen departures from the Code in a context-dependent manner. The development of additional guides and case studies would facilitate implementation.
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?: 
The ASMR can only respond with respect to health and medical research-related disciplines. In this context, the principles are sufficiently broad to adequately capture the expectations for responsible research across all research disciplines.
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.: 
We believe the draft Code is improved by not providing a rigid definition of research misconduct and instead using “breach” as an all-encompassing term to describe departures from the Code. Where breaches fit on the spectrum of severity is not always readily apparent and can be influenced by mitigating or extenuating circumstances; we don’t believe it particularly helpful to select an arbitrary point at which a departure from the Code constitutes research misconduct. In terms of potential issues, the term “research misconduct” has very strong negative connotations, so it’s possible that the absence of this label may allow institutions to downplay instances of impropriety by staff, or the deterrent to individuals engaging in such behaviour may be weakened. A strong culture of research integrity will need to be maintained to ensure that severe breaches still carry commensurate consequences.
Question 4: Do you think the process described for investigating and managing potential breaches of the Code is clearly described and practical?: 
The process for investigating and managing potential breaches of the Code is clear and well defined. The checklists and flowchart will further facilitate this process.
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.: 
We believe that a series of hypothetical case studies, along with additional guides, would be very helpful resources to support implementation of the Code. Such resources will also help ensure consistency across institutions in differentiating between minor and major breaches and the appropriate action to be taken.
Question 6: Are the mechanisms for review of an investigation clearly and correctly described in Section 7.6 of the Guide? If not, where are the inaccuracies?: 
The mechanisms for review are generally well articulated. More details could be added on the role of the ARIC and the procedure for contacting ARIC about appealing decisions.
Question 7: Please comment on which three topics you would nominate as being the highest priority and why.: 
1. Collaborative Research – As research is becoming increasingly collaborative, it would be timely to have additional guidance on managing potential breaches of the Code in context of collaborative research, particularly collaborations spanning multiple institutions. 2. Supervision – Some of the language used in the draft Code (e.g. “failure to provide adequate guidance or mentorship) is quite subjective. It would be helpful to provide guidance on what constitutes “adequate” supervision, using case studies or other examples. Further, it is important that supervisors also correctly and sufficiently educate their mentees on the responsible conduct of research and the Code. 3. Peer Review – There is currently a dearth of guidance around effective and appropriate peer review of research. This is one area that would particularly benefit from some clear, nationally-recognised guidelines.
General comments

The ASMR is broadly supportive of the modifications to the Code.

Page reviewed: 17 September, 2018