Responsible Research and the “America Competes” Act

[Post by Lise Dobrin]

Sometime late last year, we began to hear rumblings that, beginning in 2010, the University of Virginia would need to provide training in the “responsible conduct of research”[1] (RCR) to those making NSF proposals. Applicant institutions had to have a program in place, and would be responsible for verifying that all individuals conducting research with NSF grant funds had been trained. The requirement derives from something called the “America Competes Act,” which advertises itself as “Creating Opportunities to Meaningfully Promote Excellence.” Ugh, I thought. We are about to get socked with new meaningful and excellent online training modules.

Fortunately, I was wrong. The university administrators bringing this new regulation to our attention were wise enough to recognize that what constitutes “scientific responsibility” is likely to be so different in a linguistic field project than, say, in a chemistry lab that totally different approaches to training might be called for. Hence our department (a three-field anthropology department representing sociocultural anthropology, linguistics, and archaeology) was given the green light to come up with our own plan.

Official guidance on how to implement RCR training is scarce. What does “responsible conduct of research” even mean? While at NSF in late 2009, I asked around for advice and was met mostly with scrunched brows. Someone there eventually directed my attention to a very informative recent NIH Notice,[2] the take-away points of which I believe are the following:

Training should include “substantial face-to-face discussions,” “a combination of didactic and small-group discussions,” and “an ideal of full faculty participation.” The NIH guidance specifically notes that “online instruction is not considered adequate as the sole means of instruction.” Hallelujah! Music to the ears!

The subject matter should include conflict of interest; policies regarding human subjects; mentor/mentee relationships; collaborative arrangements; peer review; data management, sharing, and rights; responding to cases of misconduct; responsible authorship and publication; the social responsibilities of the researcher.

Instruction should involve at least eight contact hours. It should take place at least once during each career stage, and as early as possible in a graduate student’s career.

I am not the only one combing the federal guidance docs for clues on how to deal with the new regulation. I had to chuckle a couple of months back when I found an ad in my inbox from PRIM&R[3], the professional organization for folks in the regulatory ethics world, offering members the chance to register for their jazzy new RCR webinar. When it’s driving the market, you know it’s for real!

To the NIH desiderata I would add two more, which take into account the concerns of the “regulees.”

Efficiency. Our department calendar is already bursting at the seams, so if we’re going to achieve anything remotely resembling “full faculty participation,” we cannot be loading another eight hours of scheduled events onto people’s backs.

Inoffensive format. Scholars often bristle at administrative edicts that come down to them from on high, and for good reason. Why should administrators know better than you do how to deal with ethical challenges your students are likely to face? “Helping students think about ethical research” is something researchers might get behind. But “compliance with ethics regulations” often feels like a burdensome imposition that has nothing to do with ethical research practice.

I actually have a philosophy about ethics regulation. It’s easy to be cynical. Institutions care about compliance because they are covering their own butts. But to the extent that the regulations overlap in substance with our own professional interests, it’s only sensible to co-opt them for our purposes. That’s why I feel it’s so important for researchers to insert themselves actively into the regulatory process at their own institutions. If you’re going to have to do this stuff anyway, you might as well make it good use of your time.

So here’s what we put together by way of an RCR compliance plan for our department. Feel free to lift any or all elements that you think might work for yours!

IRB orientation (one 2-hour session), offered to incoming students in the fall of each year. Topics covered include the history and (non-cynical) rationale of human subjects regulation, overview of disciplinary and other resources on ethical research practices, and practical advice for protocol submission.

Ethics workshop for faculty and graduate students (two 2-hour sessions), held once per semester. The format followed at these can vary. For example, a faculty member or student might offer a brief presentation on the ethical challenges they face in some aspect of their research, followed by open discussion and group problem-solving.

Book discussion (one 2-hour session). Each year a rotating group of faculty and advanced graduate students leads a discussion of a relevant book on research ethics and methods such as On Being a Scientist: A Guide to Responsible Conduct in Research[4] developed by the U.S. National Academies. This handy little book is the standard reference on the responsible conduct of research, covering a wide range of topics and taking a very useful case-based approach. Plus it’s available free online. Not all of the book’s content will resonate for the members of our department, whose methods tend to fall more in the range of qualitative social science and humanities than the hard sciences presumed by the book. But perhaps students can use the book as a model for writing brief case studies of their own, which may in turn be used as materials in future iterations of the training. We’ll just have to see how it goes.

Compliance is documented by collecting signatures on attendance sheets at each event. A faculty member maintains the documentation file and serves as the departmental contact to the university research office.

Let me conclude with a few comments on what makes this program for RCR compliance attractive to me. We’re already doing IRB training; this just makes it mandatory. We’re already doing workshop-style presentations on the ethical issues in our research (which in our department is almost entirely field-based); now students just have to sign in when they show up. And they do show up, not because they need to accumulate training hours but because the discussions are so interesting! So the third component, the book discussion, is the only activity that is really new. And this I believe is serving a real need. It’s easy to go on about the complex expectations and power differentials we deal with in relation to our research subjects. But our relationships with one another are the hardest thing in the world to talk about. Having a book there as a neutral third-party might make these conversations easier to have.

So, those are my thoughts on RCR compliance. If the RCR storm hasn’t hit your institution yet, maybe you can try to take control of the situation and propose your own local plan too.


[1] http://edocket.access.gpo.gov/2009/E9-19930.htm

[2] http://grants.nih.gov/grants/guide/notice-files/NOT-OD-10-019.html

[3] http://www.primr.org/

[4] http://www.nap.edu/catalog.php?record_id=12192

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