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Draft Policies for NHMRC Committees and Working Groups Developing Guidelines Submission

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E. Submission
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Section 1 – Policies Document
Section 1 – Policies Document
2. Does the document strike the right balance between ensuring adequate expertise is available to be deployed on the committee and creating a framework to ensure conflicts are managed appropriately? : 

1.2.2 implicitly accepts that all or most experts are conflicted. Whilst this is plausible, I am not aware of empirical evidence about the absence of experts who are free of conflicts. This may be a case of too readily accepting the status quo without sufficiently exploring the availability of unconflicted experts.

Unfortunately 1.2.3 appears to give priority to diversity of ‘expertise, perspectives and opinion’ over avoiding conflicts where ever possible. Priority should be given to recruiting unconflicted experts; that is, not to accept that they will be represented on committees proportionate to their frequency in the expert community.

The NHMRC would then be taking a role in providing an incentive for avoiding conflict. One of the strongest factors in influencing experts to engage with industry is the increased sense of ‘making a difference’ that comes from having powerful and well resourced partners. If participation in NHMRC activities was an alternative to, rather than complimentary to, engagement with industry this might act as an incentive for more experts to avoid potentially conflictual industry relationships. We can be confident that this outcome would be in the best interest of patients.

1.4.1a/1.5.2e There is no evidence that there is a safe level of financial engagement; therefore all financial benefits should be declared. Smaller financial interests, especially if they are not current, may not preclude involvement in NHMRC committees but they should still be declared and available for consideration.

1.5.1d The Chair of the committee should be someone with no significant conflicts of interest. Whilst there may be situations in which an insufficient number of experts free of conflicts can be brought together to constitute the whole of the committee, I doubt that there are cases where no single expert  free of conflict can be found to chair a committee.

5. Is the amount to trigger a declaration of interests reasonable?: 

See above

Page reviewed: 5 November, 2012