By Peter McInnis
Original research forms the basis for professional practice in Canadian universities and colleges and a core activity for most of our careers. Across all academic disciplines, projects involving human subjects must pass the scrutiny of research ethics boards (REBs). In principle, such oversight is justified to ensure research participants are protected appropriately. The Tri-Council (CIHR, NSERC, SSHRC) protocol, Ethical Conduct for Research Involving Humans, or TCPS 2, explains in detail the principles and procedures required for approval. Few would contest the obligation for ethical research; however, fealty to acceptable conduct has, with the actions of some REBs, transformed it into an onerous and excessively bureaucratic barrier to timely and innovative projects.
Researchers at many universities and colleges report that approval of projects are subject to prolonged delay, repeated demands to revise and resubmit, and even queries of the rationale for the projects themselves — applications of the TCPS 2 that go far beyond the stated terms of reference. Recently, the Syndicat des professeurs et professeures de l’Université Laval (SPUL) published a survey of faculty experiences of their REB process. The results are alarming. Requesting anonymity to avoid administrative reprisal, Laval researchers spoke of the “zeal” of reviewers who questioned the expertise of widely published faculty, demanded capricious alterations in methodology, and whose “rigid and fussy” requests routinely delayed approval to the point that projects became conceptually or financially unviable. Active researchers with years of productivity, and sustained peer-reviewed funding, deliberated on whether it was worth continuing to submit projects for approval in the face of increasing administrative interference.
Beyond the technical specifics of research proposals, some approvals were withheld seemingly due to administrative fears of reputational damage to the university or college, or concerns that projects might stray into controversy and incur the wrath of provincial governments. When REBs assume the role of political or ideological filter, the humane principles of TCPS 2 have been distorted out of all proportion. Instead of a case-by-case assessment of proposals, frustrated researchers report the broad, unilateral application of expectations that undermine exploratory or innovative approaches, even where anticipated risks to participants are minor. This stop-loss, risk averse formulation of research ethics has increasingly less to do with protecting human subjects and more brand management of the workplace. The implication for academic freedom is concerning as are the societal costs of research foregone.
Recognizing that research of human subjects has widely diverse applications, and variable levels of risk, the TCPS 2 emphasizes nuance and suggests “tailoring the level of scrutiny” when assessing projects. Yet, such flexibility appears to erode in practice. In some instances, assessments are performed by colleagues without sufficient expertise, or worse, by administrative staff intent on minimizing broadly perceived risks to their institutions. This lack of proportionate risk assessment has various dimensions. Indigenous researchers comment that risk assessments interfere with analysis of the legacy of colonial oppression. Others say that they deliberately exclude Indigenous participants from their research design lest the review process be unreasonably complicated. Similarly, some researchers avoid inquiries into gender/sexual identity as barriers to ethics approval prove too onerous. In this climate of mistrust, proposals are modified and crafted to steer clear of anticipated objections. Such exclusions exacerbate existing social injustice as research objectives are curtailed or abandoned.
Researchers report that students at all levels, but especially graduate and post-doctoral candidates, are dissuaded from undertaking certain types of investigations as the approval timeline delays fieldwork while consuming scholarships. Ethics assessment must remain a core dimension of good research rather than something to “get through.” The window of opportunity for student projects is always narrow and REBs must take this into consideration. Research boards not convening regularly, or at all during summer months, compound the problem. The lack of uniformity in ethics assessments amongst Canadian institutions serves to disadvantage researchers at rigidly risk-averse universities and colleges compared to those with a more streamlined process. Research involving international cooperation may complicate outcomes and deter collaborative ventures.
Academic research with human subjects must be conducted with due respect for participants. Ethical considerations must be proportionate and assessed in a coherent, timely process for a diverse range of disciplines. One size for all should never form the evaluative framework. REBs must start from the positive obligation to advance research rather than negatively through a lens that overemphasizes liability. The fundamental academic freedom to research in one’s discipline must be upheld and not subject to inappropriate supervision and control by a university or college. TCPS 2 has much to commend it to all researchers striving for altruistic standards of comportment. Let us not allow misapplication of ethical principles and process to unfairly encumber researchers.