GAfREC, the guidance document for UK NHS RECs, has just been updated.
Until now all research within the NHS has required REC approval, even if it does not involve patients. If you want to interview a health professional or a manager about their work, you needed to go through the full rigour of a process supposedly intended to protect sick or vulnerable people from intrusion. However, the new edition (Paragraph 2.3.13) excludes research on NHS staff from REC review (“Research involving staff of the services listed in paragraph 2.3.1, who are recruited by virtue of their professional role, does not therefore require REC review except where it would otherwise require REC review under this document (for example, because there is a legal requirement for REC review, or because the research also involves patients or service users as research participants”). Is this cause for celebration? Has a research regulator really rolled back the mission creep that seems inherent in ethical regulation?
Personally, I am not rushing to join the applause from some colleagues. The same clause underlines the duties of employers to control access to their staff – without any acknowledgement that, as public bodies, NHS organizations might also have a duty of accountability to make staff reasonably accessible for research purposes. In addition, paragraph 1.3.4 underlines the potential role of University Research Ethics Committee (URECs) in reviewing studies that are not within the scope of the NHS system. On my reading, what we have is actually a cost-shifting measure, where the NHS is trying to achieve economies by pulling back its own activities and leaving URECs to pick up the work. Access to NHS employees will still need to go through the R&D approval system for each organizational unit involved, which has often been more obstructive than the REC system. Does anyone seriously believe that the R&D departments will not demand evidence of UREC approval?
In fact, we may find ourselves looking back nostalgically to the NHS RECs, which, while often justly criticised, have tried to take the criticisms on board and to rein in some of the more ignorant judgements on social science research that used to mark their practice. The National Research Ethics Service has worked actively to promote a more professional approach and to encourage autonomous local committees to engage in training and to show respect for the diversity of proposals brought to their attention. In abandoning the field to URECs, the NHS is leaving social researchers at the mercy of a fragmented approach, where amateur committees exercise confused responsibilities with little or no accountability other than to line management in their institutions. The results can be every bit as ignorant as a backwoods NHS REC and profoundly illiberal when review is used to silence research in the interests of reputation management. Indeed it would not surprise me to see UK universities using URECs as ways of making life difficult for dissident staff. As the Carl Elliott case in Minnesota has shown, some institutions have difficulty in recognizing that freedom to express ideas, including criticism of IRBs or URECs, can sometimes properly be upsetting to colleagues. If we were only allowed to say things that never affected our professional relationships with other faculty, what would be the point of a university?