NHMRC Public Consultations

Skip Navigation and go to Content
Visit NHMRC website

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

Personal Details
This submission reflects the views of
Organisation Name: 
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?: 
The Australasian Council of Deans of Arts, Social Sciences and Humanities (DASSH) welcomes the new Code and its focus on high-level principles, responsibilities and expectations. This direction has produced a more user-friendly document that will be easily understood by researchers, universities, and funding bodies.
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?: 
On the whole, DASSH believes that the principles adequately meet the needs and expectations of the arts, social sciences and humanities (ASSH) disciplines. However, we do have a concern with one of the proposed responsibilities for researchers. R21 states that researchers will “cite and acknowledge other work appropriately and accurately and obtain permission for the unpublished work”. While we are supportive of the reasoning behind this responsibility, DASSH is concerned about two aspects of this responsibility: the scope of the responsibility and obtaining permission for the use of unpublished work. Potentially the scope of this responsibility could be very broad. Does the responsibility cover unpublished work already in the public domain, unpublished work not in the public domain or both? A number of the ASSH disciplines (for example, history, art, anthropology, sociology) rely on the unpublished material housed in libraries, archives, museums, etc for their source material. Obtaining permission for the use of this material can often be extremely difficult or even impossible. While it can be assumed that if data is publicly available in this type of setting that it does not require further permission, DASSH recommends that this is explicitly stated in the Code along with what is meant by “unpublished work”.
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.: 
On the whole, DASSH does not have issues with this approach in the draft Guide. We feel that the guidance is clear, concise and user-friendly. However, we are concerned by the inclusion of “mentorship” in the example of breaches of the Code related to Supervision. The proposed text reads: “Failure to provide adequate guidance or mentorship for researchers or research trainees under their supervision” (Example iv, p.3). The wording of this example is very vague and raises a number of questions. What is “adequate”? What is “mentorship” as opposed to “guidance”? In practice, it is assumed within our disciplines that supervisors supervise researchers and research trainees and therefore provide guidance to them, while someone in a position of authority or expertise in the field may mentor, but not be a formal supervisor. In these cases, how would this operate in practice? DASSH recommends clarifying this example.
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.: 
There are costs and benefits in using case studies to assist in the investigation and management of potential breaches of the Code. On the one hand, the case studies could be a useful guide, point of reference and provide precedents for those involved in investigating and managing potential breaches. On the other hand, the development of case studies will impose a burden on the NHMRC and ARC to develop and produce the case studies. The Guide to investigating and managing potential breaches of the Australian Code for the Responsible Conduct of Research is comprehensive in describing a model process for investigating, managing and resolving such concerns or complaints and providing examples of the range of behaviours that can constitute a breach of the Code. DASSH is concerned that the cost of producing case studies would outweigh the benefit derived from having them.
Question 7: Please comment on which three topics you would nominate as being the highest priority and why.: 
DASSH agrees that authorship and data management are high priorities for further guides to support the implementation of the Code. We support the NHRMC, ARC and UA’s proposal of having the next two guides focus on these areas. The next three topic areas that DASSH believes to be of highest priority are: 1. Supervision; 2. The role of research integrity advisors; and 3. The role of research integrity offices. Supervision is a key area in research across all disciplines and is an area of high risk. Producing guides on the roles of research integrity advisors and research integrity offices would provide guidance and assistance to those taking on these roles within universities and research institutions.

Page reviewed: 17 September, 2018