A Code of Ethics for Institutional Review Boards
By Norman M. Goldfarb
Institutional review boards (IRBs) focus on the ethical issues of people and organizations that conduct clinical research, as defined by applicable laws, regulations, guidelines, etc. However, the IRB itself, along with its individual members (and staff), have their own ethical challenges. A concise, common-sense statement of what constitutes ethical conduct by an IRB and its members — a code of ethics — could improve the quality of IRB reviews. Since IRBs are only one part, albeit a very important part, of a human subjects protection program, the code of ethics should be adapted accordingly. The code of ethics proposed in Figure 1 focuses on ethical conduct, not the conflicts of interest (COIs) and other potential causes of unethical conduct, which constitute a separate, very complex topic. The proposed code of ethics assumes that IRBs have instituted COI policies and procedures.1 Most of the individual items in the proposed code of ethics are probably followed widely, although perhaps not rigorously and universally. Is an IRB code of ethics necessary? To the extent that an IRB’s policies and procedures incorporate the contents of a code of ethics, a separate code of ethics is redundant. However, even in this case, a separate code of ethics can clarify the ethical responsibilities of the IRB and its members. This article is not meant to be the last word on the topic of an IRB code of ethics. Rather, it is intended to stimulate discussion about what constitutes ethical conduct by IRBs, lead to the adoption of codes of ethics superior to the one proposed here, and promote ethical conduct by IRBs and their members.
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