The other day I was asked to comment on the "Mission Creep" white paper. The paper recommends "...focusing on those areas of research that pose the greatest risk, such as biomedical research, while removing or reducing scrutiny of many fields within the social sciences and humanities that pose minimal risk." This is based on the assumption that the primary purpose of IRB review is to protect subjects from risk. Beneficence, which addresses the relation between risk and benefit, is only one of the three Belmont principles. There are respect and justice issues even in minimal risk, innocuous research. I believe that all research activity, even innocuous research, requires some sort of independent, objective review. Reducing the oversight over minimal risk research jeopardizes
The problem that this paper is responding to is not IRB review per se, but IRB review that is unduly burdensome and that imposes unreasonable requirements. So, while claims that IRB review is not necessary for minimal risk research are not reasonable, IRBs are somewhat responsible for the attacks on IRB review. I have long argued that the regulations provide sufficient flexibility for the efficient and appropriate review of minimal risk research. IRB review of such research does not have to be burdensome or unreasonable if IRBs appropriately utilize the flexibility in the regulations. The horror stories that social and behavioral researchers quote in their attacks on IRB review are true. I have seen institutions where expedited review takes longer than full review and where IRBs have imposed written consent forms on telephone interview research. These are IRBs that a) don't understand social and behavioral research, b) don't know how to use or are afraid to use the flexibility in the regulations, and c) don't pay sufficient attention to the efficiency of their procedures.
The White Paper correctly recommends that IRBs receive better guidance on how to review non-biomedical research and that there needs to be increased sharing of best practices among IRBs. However, critics of IRB review should focus their attention on educating IRBs on the appropriate review of non-biomedical research rather than trying to reduce IRB oversight of such research.