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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: 
Bionics Institute
Specific comments
Specific comments: 
Principles in Code

P7 Accountability for the conduct of research

  • ‘Researchers will consider the consequences and outcomes of research prior to its communication.

    1) It is not clear to us what is meant by this point. 2) This point seems in part to contradict P3Transparency in declaring interests and reporting research methodologies and findings’ and R19 ‘Disseminate research findings responsibly, accurately and broadly.


Responsibilities for Researchers in Code


  • ‘Ensure that authors of research outputs are those, and only those, who have made a significant intellectual or scholarly contribution to the research and its output, and that they agree to be listed as an author.’

As with the current version of the Code, it difficult to define what substantiates a ‘significant’ contribution.

We would like to see the authorship criteria brought more closely into line with internationally recognised criteria (such as those defined by the International Committee of Medical Journal Editors [ICMJE]). (http://www.icmje.org/recommendations/browse/roles-and-responsibilities/defining-the-role-of-authors-and-contributors.html)

In particular, we believe it is important that all authors should provide final approval of the version to be published, and agree to be accountable for the work they contributed.

We think that the provision of a guide focusing on authorship (including how to deal with authorship disputes) should be a high priority for the NHMRC Code Review Committee.

Responsibilities for Institutions in Code

Four out of twelve of the responsibilities (R9 to R12) relate to breaches of the Code. We recognise that this is an important aspect of an institution’s responsibilities. However, we question the need for these responsibilities to be listed at the proposed level of detail in the draft Code, particularly with the provision of a detailed Guide. We suggest responsibilities R9 to R12 be condensed into one or two responsibilities in the Code.


  • ‘Promote the prevention and detection of potential breaches of the Code. This should include identifying and training Research Integrity Advisors (RIAs) who provide advice to those with concerns about responsible research conduct.’

Training in research integrity matters, is hard to come by. We would like to see the NHMRC (or other organisations) provide easily accessible training to enable institutions to comply with training requirements (see Consultation Question 5).

Guide Section 4

4.2 Principles of procedural fairness

(iii) Impartial

‘Investigators and decision-makers are to be impartial and any conflicts of interest that do, may, or may be perceived to jeopardise their impartiality should be disclosed and managed.’

 We agree with the principles of procedural fairness as set out in the draft Guide. However, impartiality may be difficult for institutions to deal with, particularly given the collaborative nature of research. Additional guidance on how to deal with conflicts of interest would be helpful.

4.3.1 Research integrity advisors (RIAs)

‘Institutions should offer regular training to RIAs to maintain their skills and knowledge base’.

 We would like to see the NHMRC (or other organisations) provide easily accessible training to enable institutions to comply with training requirements.

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 like the new approach to the Code, and think that the proposed structure makes it more accessible and therefore more likely to be utilised by researchers, which is positive. Having detailed guides to support various aspects of The Code is also welcome. The draft guide to managing breaches of The Code is a very good resource, and is an improvement on the guidance provided by the current version. These detailed guides will also promote greater harmonisation across institutions and how they deal with breaches of The Code. We note that within Responsibilities of Institutions there is no longer reference to establishing agreements to govern collaborative research (Section 8 of current Code) although it will be a topic for a guide in the future (which is welcome).
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, we believe the principles 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 understand that the intent is to provide institutions with some flexibility around their own processes. Since most research has a collaborative component, a possible issue in not having a ‘universal’ definition is that it could complicate inter-institutional cases of research misconduct/code breach.
Question 4: Do you think the process described for investigating and managing potential breaches of the Code is clearly described and practical?: 
Yes. This is a welcome and more accessible guide than provided in the current Code.
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.: 
Yes, case studies would assist us. An ideal additional resource would be the establishment of a single website that supported all aspects of Code, and included all relevant documents, case studies, RIA training modules, and perhaps a secure RIA portal where anonymous discussions could take place. An alternative to the latter might be a central, independent office that could provide RIAs and RIOs with advice and support - a possible expansion of the role and scope of the current ARIC. The Office of Research Integrity in the USA provides such a website and excellent resources, and something of this type in Australia would be very welcome.
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?: 
More details of the review mechanism would be useful.
Question 7: Please comment on which three topics you would nominate as being the highest priority and why.: 
We agree that the next two guides should focus on authorship and data management. In our experience, researchers commonly experience difficulties in these areas, particularly the first, and they should remain a high priority for the Code Review Committee. In addition to these, the three topics we nominate are: 1) Collaborative research; because agreements can consume a disproportionate amount of time, and administrative and legal resources. A harmonised approach and a simple, concise template for a multi-institutional agreement would be welcome. 2) Intellectual property and copyright; in our experience there appears to be much misunderstanding around these issues, including issues of authorship. 3) Conflicts of interest; because these can be difficult to manage, and affect a broad range of activities and roles.

Page reviewed: 17 September, 2018