The complaints include the tedious, time-consuming decisions for very routine proposals. No doubt convoluted clerical processing can be a contributing factor, but there is more.
Most behavioral researchers also feel that much of the delay stems from the extension of policies that (may or may not) cover medical research to the rest of the campus. No doubt this campus-wide umbrella "simplification" contributes to some of the problem, as proposal reviewers try to apply frequently inappropriate or irrelevant guidelines to psychological research. But there may be more yet.
I make some observations on this here, why this might be happening, and what the consequences seem to be. Although the comments here will be illustrated using deception in psychological research, the issues are quite general. Yes, these are just my opinions, hard-earned ones at that, and they do not represent the opinions of my employer, nor any other VIPs in suits. However, others are beginning to express concerns too, such as this Lingua Franca article, Don't Talk To The Humans. Furthermore, IRBs are an issue in Morton Hunt's book, THE NEW KNOW NOTHINGS, and arguably these problems are yet another manifestation of THE SHADOW UNIVERSITY. Martin Gross has also written around many of these issues as well, in THE END OF SANITY. Jonathon Rauch's KINDLY INQUISITORS doesn't say much directly about ethics review boards, but his points show how fundamentalism from all perspectives is being used to thwart scientific inquiry. And, in a speech at the Harvard Law School Forum, Moses himself has spoken out on these matters.
Interestingly very little of the discussion is coming from within academe, a fact that would not surprise Hunt or Gross I suspect. One of the exceptions is THE BETRAYAL OF INTELLECT IN HIGHER EDUCATION, although the author waited until retirement to speak out.
Yes, Virginia, I remember research before Institutional Review Boards (IRB). No one wanted to walk past psychology labs, as shrieks and rattling chains could always be heard through the bolted doors. Bullwhips cracked in the air, and the campus was full of armed storm troopers marching hand-cuffed students off to whatever happened behind those closed doors. Eventually concerns about these Frankensteinian practices gave birth to IRBs and REBs.
Wonder if any of the participants in Murray's research did anything outstanding, like win a Pulitzer Prize, found Microsoft, become President, or whatever? And how many terrorists and other no-good-nicks managed to develop without participating in Murray's experiments? Just curious what the comparison(s) should be here, before we begin using this speculation as a reason for IRBs to expand or justify their efforts.
These are sometimes known by other names, such as Research Ethics Boards (REB), etc. They often seem named in some fashion to obscure the nature of the activity; for example, why doesn't an IRB review "institutions" rather than research proposals, as a naive person might suspect?
At other times they seem named so as to establish the nobility of their activity as so exalted as to be beyond reproach (ala Human Rights Commissions) - Research Ethics Boards, who can oppose "ethics"?
|Actually we all should, until we know WHOSE ethics, what authority ORDAINED them, and WHO IS WATCHING these gatekeepers -- as it is, there is no way to hold the IRBs accountable, much less the individual members.|
Another reason, of course, is that even more regulation is clearly on the way.
Why do I suspect that the Junk Science web site service will continue to grow? Perhaps because it provides such a valuable public service, as clear thinking protects the public in a far more useful and efficient manner than more regulation by uni-dimensional ideologues?
Paperwork reduction act? Paperless office? Yeah, sure, bah, a pox on your house for believing such nonsense! Consider the procedures for expedited review ... OK, how much of it was tailored to medical research (90%?) and how much applied to social science (5%?) -- now does that give a whiff of what our problem might be?
In the early days of IRBs, the guideline was explicit that the research not expose the subject to risk GREATER THAN EVERYDAY LIFE.
1. When did this qualification cease to be explicit?
It is interesting to consider this criterion (everyday risk) with regard to the everyday deceptions we tolerate without incident much less without catastrophe, such as the following ... you couldn't get them approved by an IRB today (go ahead, try it!) ... think about that ....
Santa Claus Halloween & the Great Pumpkin Easter Bunny Tooth Fairy Disneyland Jurassic Park World Wrestling Federation Clark Kent Houdini, Mandrake, David Hemming, Penn & Teller, ... I did not have sex with that woman. ..., but I didn't inhale. Read my lips, no new taxes. I am not a crook. I invented the Internet. Covert operations I will kill the GST. I talk to my homeless friend. Stornaway will become a bingo hall. Scholar-athlete Equal justice for all OJ found innocent That's such a nice dress (hairdo) (tie) (drapes) ... Let's do lunch False teeth, falsies, girdles, codpieces, toupees, glass eyes, contact lens, ... Nose jobs, face lifts, liposuction, silicon implants, hair dye, ... Cross-dressing (Tootsie), trans-gendering, ... Cloning. Placebos ..... Area 51 Elvis impersonators Milly Vanilly Lip sync music It was just driven by a little old lady, to church on Sundays. (athlete x) is worth 100 million dollars Free health care Paperwork reduction act Paperless office Y2K disaster Lies, damn lies, and statistics -- "Statistics show ..." But Mom, he hit me first The dog ate my homework. My grandmother died, so my homework isn't done. I wasn't speeding. Truth in advertising. Mandatory volunteering Do you have anything to declare? Separate but equal Tastes as good as the real thing. Lose weight without dieting or exercise Lifetime warranty As good as new. No hidden costs Based on a real-life story Docu-dramas and REAL-TV No sales agent will call Will you still love me tomorrow? Trekkie conventions The check is in the mail. Guns and butter A chicken in every pot. Peace in our time. War to end all wars. Chance of a lifetime ... Satisfaction guaranteed ... Buy one, get one free According to a reliable source ... Pop quizzes Dimpled ballots ---- Candid Camera Teaching counts as much as research toward tenure. Income tax: just a temporary war tax ... Payroll withholding: just a temporary war tax -
And this is not to mention that the everyday risks in third-world countries are different from Mister Rogers' Neighborhood in North America. The everyday world, anywhere, is a scary place to go, no wonder some people don't want to live there!
As regards the fourth though, it is possible to characterize the result of removing this sensible barometer of risk in regard to deception: with this (everyday life) qualification in the decision process, the social engineers on the IRBs would find it harder to hassle (certain) researchers, whereas with it gone they can more readily delay and even suppress research on certain topics.
Sound too conspiratorial? Then consider an old strategy for making sense of nonsense. That is, Grandpa always said it is helpful to simply ask "WHO BENEFITS" (who profits - follow the money, or who gains power?). In the absence of empirical data on a topic, rhetoric, disinformation and outright misinformation come to the fore. Political lobbying becomes more effective in shaping policy decisions, with rationales based on narrow, idiosyncratic agendas uncomplicated by actual data. Sound familiar?
Perhaps this was not the GOAL (frankly, these folks may not be all that bright!), but it has become the OUTCOME. Some examples.
It is informative that quite often IRBs are (apparently) unaware that APA and CPA have well-codified ethics guidelines, or they are dismissive of these when they are informed. It seems nothing is worth noting unless it has been developed by and for the Medical Establishment - then what is good for the Medical School is good for the whole campus. (Wasn't Frankenstein in a medical school? But I digress.)
As a result, IRBs bash ahead "solving" problems that have already been solved in many cases, and pondering problems that are all too often merely hypothetical in other cases, and otherwise assuming that worst case scenarios will be the norm -- the "ethicist syndrome".
|Actually, let's reword that: IRBs are busy "finding" problems, "solving" problems being the least of their concerns. Please, STOP thinking of these folks as your "colleagues," because they are not. Let's keep in mind that the ethicists and other ideologists don't DO research: They actually have a vested interest in keeping the discussion (evaluation, "debate") ongoing -- hey, as long as there is no research, there are no ugly facts (data) to contradict or settle the issue(s).|
I confess, I have had little success identifying the "benefits" of my own research, much less research in other venues across campus. Nor am I willing to believe that someone in another department is better able to judge the "benefits" of my research than I am. And certainly not the "non-scientist and an individual not affiliated with the institution" reviewers recommended for IRB membership. (This goes double for judgments of research design and the like.)
What happens then, is that because "benefits" are difficult to identify, they are either denied to exist, or a reviewer begins to make judgments of "importance" or "desirable" or some such more nebulous interpretation of "benefit" -- VALUES.
What this leads to, intentionally or not, is the application of the reviewer's personal VALUES in the decision of merit. Clearly this is the only criterion the non-academics CAN bring to the evaluation (and when pressed they may admit that), but it also happens for academics who are in another discipline (although they may be less inclined to openly acknowledge they are out of their element than any lay person!). This danger is aggravated by having medical research criteria intrude into the assessment of behavioral research: those criteria don't fit, so the reviewer has to comply with the request to review by adopting some other standards, implicitly or explicitly.
VALUES opens a large can of worms, because now a reviewer can fault the merits of the proposal when it doesn't match their bias in regard to methodology or any number of other considerations (notably ideology) that have no connection with everyday-risk nor even a benefit/risk analysis. This intrusion of VALUES is not only unconnected to BENEFITS but simply irrelevant to whether the research poses any risk to the subjects (which is the only mandate these IRBs have ever really had).
|Once the Medical School "ethicist model" takes over the IRB, it is no longer a question of personal values MASQUERADING as benefit in some implicit manner, the values criterion becomes EXPLICIT and deliberate. But it's still irrelevant to "benefit" and "risk".|
|We must keep in mind that, by definition, ethicists and ideologists are concerned with the world "as it OUGHT to be" -- which denies any relevance of the real world and its inherent everyday risks! Reality contact is generally considered a criterion for good psychological health, but it doesn't seem as important to IRBs as does world building and social engineering.|
The traditional rationale for doing research is that we are trying to DESCRIBE the real-world, not create an ILLUSION of a better world. It would seem easier, to me, to bridge to a better world if we had an accurate description of the everyday world as it really is. So I have to wonder who has lost contact with reality here, and why is there such disdain for the everyday world?
Wait, Nostradamus is sending me a previously lost quatrain .... how long will it be before you have to submit your manuscripts to an IRB before you submit them to a journal, just so they can be sure you did what you said -- and that you interpreted it "correctly"? One year? five years? Or maybe it would just be easier to mandate that journal reviews have to include one reviewer who is an ethicist?
RISK REDEFINED AS LIABILITY
In the beginning, the concern for IRBs was "risk" with regard to consequences to a research participant (termed a "subject" in those less enlightened times; at least we didn't call them "patients" or "clients" -- or "customers," as we are now encouraged to view students).
Gradually, perhaps because such risks are virtually nonexistent in behavioral research, reviewers began to apply another question: is there any LEGAL risk, to the institution.
|If liability to the institution is to be an issue at all, then turn the review over to the institution's legal staff and get a professional decision (what else do they really do?). Forcing a task on unqualified people is bound to slow things down, not to mention yield problematic results. Just remember though, lawyers are schooled to charge by the billable hour, so they are not encouraged to do speedy decisions -- no solution there to the bottleneck and delays.|
We know that DEMAND CHARACTERISTICS in situations are important. The demand in a review process is to "find risk", explicitly or implicitly. FIND-RISK is not at all the same as IS-THERE-EXTRA-RISK. Failure to find risk then can translate as personal failure by the reviewer, that is, incompetence. So reviewers stay at it, as long as it takes, and dutifully find something to question, anything, to feel as though they have demonstrated their prowess.
Then having finally settled on something, no matter how trivial, a confirmatory bias settles in, and defensiveness precludes any retreat.
Of course, whether the members of such a board are elected (and by whom), appointed (and by whom), or volunteer will have considerable bearing on whether they bring expertise or ideology and personal values to the table.
Then, finally, why the proclamations from on high, that is, how do the grant agencies profit? Absolute power corrupts ... does that ring a bell? Not all the social engineers are on the local IRBs. Too many of these folks read 1984 and saw, not a horror story, but a GAMEPLAN, and saw in Big Brother, not a monster, but a MENTOR.
(Hmmm, there's that misbehavior in medical schools again, creating issues for the whole campus. Maybe if we didn't have medical schools we wouldn't need IRBs? Or maybe we would have to shut down the law schools too? OK, you still have one wish left ...)
|One must acknowledge that when outsiders in the form of Big Business or Big Science come on stage, their "ethics" are not controlled by IRBs or anything other than the bottom line. When you make a pact with the devil, don't be surprised when he comes calling. Some refer to this as the KEPT UNIVERSITY. Grandpa called 'em "hookers" -- he always did have a way of cutting through the bafflegab.|
For a good example of this process at work, consider what happened to one academic who did the ethical thing and blew the whistle on bad drug-test results, then tell me once again why the whole campus should adopt the values inherent in the medical model and its sponsors.
And then there is the sad role of an IRB in the 1994 suicide of Justine Sergent, a bright young neuropsychologist in Montreal.
|The ethics/values of concern to Big Business and Big Science may not even be appropriate in absolute terms, for many of us, but they are so irrelevant and convoluted that they invariably add inordinate delay to the review process for psychological research proposals.|
It has always seemed to me that much if not most social science research has been conducted without grants, and much that was conducted with grants could have been conducted without?
Ditto for those administering the grant agencies: in their youth it was "defy authority", now THEY are the authority, and if you defy THEM, oh my, the sanctimony and smugness is something to behold. Bullying by lawyers (and bureaucrats) is still bullying (Toffler; Powershift). Me thinks Monty Python would consider a mooning to be the appropriate token of respect.
Junior faculty have little choice but to conform or at least appear to opt in. Even senior faculty who challenge things face assorted formal and informal censure from the politically correct truth squads. It's hard to see how such coercion differs from other workplace bullying; with the strong leadership of present university administrations we can expect more of it rather than less in our future. It may be useful in communicating with the public to talk less about "academic freedom" and more about "workplace bullying."
THE NEW PURITANS?
|Hmmm, could it be that the stated intentions of IRBs involve deception(s) more than we would expect in everyday life?|
A classic psychological explanation may account for why IRBs have such low thresholds for deception, one deriving from Freudian conceptions such as repression and then projection ... "me thinks the lady protests too much perhaps?" Of course, if Shakespeare would have trouble with his bawdy plays, imagine the IRB trouble Freud would have with childhood sexuality.
Does the world really need such Orwellian curators of ethics? Do you really think they will of their own accord get back to the original mandate? Do you really think they care what we think? Do you really think they want an open inspection of what they do? Some famous quotes on deceit and deception
Whatever the motivations, the OUTCOME is that the quality of the database is not what it could be, and it stands to get worse as IRBs continue to try to proscribe what constitutes good research based on values and ideology. In the absence of a good database, decisions will increasingly be made on the basis of rhetoric and Right Thinking. Consider an example of data corruption in school research.
The IRB enterprise has become monolithic, and the aloofness or outright imperial arrogance is not encouraging with regard to change from within or without. These folks have a world vision, a missionary zeal, and their grandiose ethicist vision is increasingly disconnected from the original, minimalist mandate of monitoring subject-risks greater than everyday life. Even your daily bread is at risk.
Who profits? |
Sound familiar? .... SOME EXEMPLARS ....
Maybe we should just do our research in the real, every-day world, not the IRB world?
There is actually a legacy of naturally occurring research, including phenomena such as the Bystander Effect, the Zeigarnik Effect, etc. Are there other ways to do psychological and similar research "off campus"? Maybe we will soon be limited to being voyeuristic researchers as we huddle around television shows such as Candid Camera, The Survivors and Big Brother, not to mention all those web cams? Or Jerry Springer and Jenny Jones for aggression? It's not my remote control, it's my data generator?
Maybe we are looking at a future when we will have to depend on the private sector, unimpeded by IRBs, to do behavioral research? After all, the business model of the campus is all the rage these days. Of course, the private sector won't be able to publish it in the journals that have been co-opted into this draconian (1, 2, 3, 4,) enterprise. However, the private sector tends not to treat knowledge as something to be shared anyhow. I'm sure they would be willing to sell data to us, that's how it is in the everyday world of business.
Or maybe the Government will have to step in and do the research for us, if we can't be trusted to handle sharp objects like data. Ever notice how the Census Data and Tax Data are not collected voluntarily? And do you feel fully informed about what these databases are used for, and how confident are you that they are preserved anonymously at all? How confident are you of the validity of press releases based on these? Have they undergone peer review -- perish the thought. Some government agencies even take a page from the private sector, and charge us for this information (e.g., Stats Canada), whereas others will release it ... though you may have to file a Freedom of Information lawsuit. Isn't that nice -- share and share alike, boys and girls.
In fact, Governments have a long record of doing research that IRBs would not approve for the rest of us, including LSD experiments and other things. Big Business/Science at least has bottom-line ethics, but Big Brother has yet another, murkier agenda. And all of the BIGs have ways to expedite the IRB bottleneck, including ignoring it altogether (rather like expecting criminals to register their guns, eh?).
Maybe we will become increasingly dependent on our colleagues off-shore to take up the slack?
Interestingly, journalists can approach anyone and gather data (e.g., browse the trash) without an IRB. Is this acceptable because Journalism Schools do a better job of ethics and methodological training than a graduate psychology program?
Should we all just get hobbies, relax, and let Big Brother think for us? One could just shrug, and concede that proscribed research is yet another indication that today's university campus is becoming irrelevant, or at best derivative rather than original in thought, as the VP-Finance becomes more influential than the VP-Academic.
Dr. Frankenstein left campus. Dr. Jekyll and Dr. Moreau too. Maybe it would be more parsimonious to just send the medical school and lawyers off campus? Say, let's send them and the IRB visionaries to a vacation-retreat on that island with Dr. Moreau ....
Take-home: If social science research becomes harder to do on-campus than off-campus, one does not have to be B. F. Skinner to project that such research will move off-campus.