The historians are "supportive of the changes that have been made in the second edition and consider it a very good policy paper." They particularly appreciate the various passages sprinkled throughout the statement noting that not all research fits into a standard form, and that research ethics boards need to maintain flexibilility.
But, taking a broader view, the historians are dismayed that these passages appear as mere exceptions to general rules designed for quantitative, especially medical, research. As they put it:
While there is no question that the ethical issues arising from clinical or quantitative research must be addressed, the effect of this emphasis is to marginalize qualitative research in the humanities and some social sciences. Indeed, the TCPS-2 casts all qualitative research as the exception; something best exemplified by the inclusion of Chapter 10, "Qualitative Research." There is no parallel explanation of quantitative research; perhaps because it is considered the "normal" research practice everyone is familiar with.
Casting qualitative research as exceptional puts individuals undertaking such research – like historians – in the position of asking for exemptions from REBs. REBs, like all administrative tribunals, are likely to look on requests for an exemption from the guidelines with suspicion, making the bar higher for those undertaking qualitative research higher – simply because of the kind of research they are doing, not its quality. Not only will historians have to demonstrate the soundness of their particular research designs, but they will also have to establish that the norms of their professional practice are legitimate. In our view, this places an undue burden on our profession and on all those engaged in qualitative research.
This passage neatly summarizes most of what has gone wrong in the regulation of research in the social sciences and humanities over four decades in countries around the world. Medical regulators have written rules based in clinical medical practice, then imposed them on other fields in a way that defines those fields as abnormal, and therefore suspect. Seeing this flaw as intrinsic to the ethics review system, the Canadian Historical Association understandably "urge[s] the Advisory Panel to consider the position of the Oral History Association (US) which since 2003 has argued that oral history should be excluded from institutional review boards."