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Department of Defense

Excessive Human Subjects Reveiw Board Reqs

I am in no way debating the usefulness or ethical obligation of human subject review boards, especially in DoD funded clinical research. However, the current system requires an investagator to submit IRB packages for approval at the institution the researcher is employed at regardless of whether the work is actually being conducted within that site. This requirement simply fails to reflect the collaborative nature of science, a nature which is becoming more pronounced each year thanks to online collaboration between universities and research institutes. This results in a number of investigators needing to submit every single project for IRB review twice: once at the site which the study will actually be conducted at and once at the site where the researcher is listed as faculty even though that site has no authority over the study. While the implementation of IRB net is supposed to streamline this process so that researchers can simply share IRB packages between sites, the IRB's themselves continue to demand site-specific forms be submitted. This means researchers must double the work they do for every new study submitted, every continuing review (which can come as often as six months) and every single amendment. This cumbersome process does not serve the participants in the research, it does not serve the funding agencies paying for it, and it certainly does not serve the researchers doing the work. All of this extra work could easily be avoided by requiring researchers to get IRB approval ONLY at the sites at which the work will be conducted. This would eliminate a huge amount of inneficiency along with the extra personnel and wasted time that goes with it.

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Idea No. 230