NHMRC Public Consultations

Skip Navigation and go to Content
Visit NHMRC website

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

ID: 
31
Personal Details
First Name: 
Klaas
Last Name: 
van Dijk
Specific comments
Specific comments: 
Preamble in Code

See my e-mail of today with an extensive list with comments / remarks / proposals / backgrounds about a large amount of the different sections. An identical version of this e-mail (a Word document) and the attachment (a PDF document) are attached to this online submission (I was not yet aware that attachments could be added to the online submission when I had sent you this e-mail, please excuse me for this misunderstanding). Please contact me immediatey in case there are errors and/or mistakes in my texts.

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?: 
No and no. It is a disaster that empty terms like 'advice on implementation' are used. See my e-mail for more backgrounds.
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?: 
Yes and no. See the comments my e-mail for details.
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.: 
This is a a horrible decision and must not be implemented. See my e-mail for details / backgrounds / proposals and for details about my experiences with contacting various Australian universities about research integrity issues. I strongly underline the statement of [NHMRC has removed third party information] (see e-mail for details) about an agreement on a definition of scientific misconduct. See http://www.lup.nl/product/tussen-fout-en-fraude/ for more backgrounds about a definition of research misconduct.
Question 4: Do you think the process described for investigating and managing potential breaches of the Code is clearly described and practical?: 
Yes and no. It is excellent proposal that "The process of making a complaint should not be onerous." No, see for backgrounds / proposals my e-mail.
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.: 
See my e-mail for lots and lots of proposals and items which have the highest priority to be implemented immediately (at least towards my opinion).
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?: 
No. See my e-mail for comments / remarks / proposals.
Question 7: Please comment on which three topics you would nominate as being the highest priority and why.: 
The new Code must towards my opinion contain: (1) a part in which it is clearly stated that it is mandatory for all Australian researchers that they work always, and always for the full 100%, in full compliance with the new Code, (2) mandatory parts about obligations for data sharing, (3) mandatory parts about obligations for storing raw research data for a period of at least 10 years, (4) a wider definition of the type of acting / behaviour ('research') which falls within the scope of the Code. See my e-mail for comments / remarks / backgrounds / proposals, etc.
General comments
Comments: 

See my email with an extensive list with comments / remarks / proposals / backgrounds and with my experiences with contacting various Australian universities about research integrity issues. Note that this email contains an attachment (a PDF document) and note that this attachment is an ingral part of my submission. Please contact me immediatey in case there are errors and/or mistakes in my texts.

Page reviewed: 17 September, 2018