Posted on behalf of Liz Horn, Director of Genetic Alliance‘s BioBank. Read more about Liz on our ‘Experts’ page!
The informed consent process and the Institutional Review Board (IRB) are traditional systems for managing research risk. IRBs, established by the National Research Act in 1974, are charged with approving, monitoring and reviewing research, with the primary goal of protecting the rights of human subjects. IRBs are mandated by the Federal Government as part of the Code of Federal Regulations (CFR) (Part 46 [Protection of Human Subjects] of Title 45 [Public Welfare] and FDA regulations on IRBs at 21 CFR 56). (This document compares the FDA and HHS Human Subject Protection Regulations.)
Broadly, each research study must consider the following:
- Respect for persons – How can our research processes enact respect?
- Beneficence – How can we assure our research is achieving benefits? And clear benefits for whom?
- Justice – How can we proceed equitable and fairly while addressing current injustices in the system?
Specifically, according to the ICH GCP guidelines, IRBs should review the following: the research protocol(s) and any amendment(s), all written informed consent document(s) and any document revisions, recruitment procedures for participants including advertisements, all written information provided to participants, the investigator’s brochure, any available safety information, information about payments and compensation available to participants, the investigator’s current curriculum vitae and/or other documentation evidencing qualifications, and any other documents that the IRB may need to fulfill its responsibilities. IRBs also review the research protocol and other related documents at regular intervals (usually at least once a year). The principal investigator is responsible for reporting to the IRB any protocol deviations or changes to the protocol, all adverse reactions, and any new information that may adversely affect the safety of the participants.
Several recent events have influenced the public narrative on research ethics, including Rebecca Skloot’s book “The Immortal Life of Henrietta Lacks”, the destruction of 5 million discarded newborn blood spots in Texas, and the Havasupai/ Arizona State University settlement. Given these events, it is possible that business as usual practices can cause harm, and we often cannot anticipate what harm looks like.
This suggests that traditional systems for managing risk, including IRB review and the informed consent process, may not be sufficient, and additional standards and stewardship practices may be needed to guide us. As good stewards, we must engage our community and the public, be transparent about research practices and intentions, communicate openly and clearly, and ask permissions before using samples outside of original scope or intentions.
- Do you think our traditional systems for managing risk are sufficient?
- How do we manage the process of informed consent with low levels of health and science literacy?
- What rights do individuals have to their data or samples?
- Should we ask individuals permission to use their samples in other ways? If yes, what infrastructure is needed?
