Palys and Lowman find the latest draft to be an improvement over the December 2008 version, but they remain dissatisfied with elements of its treatment of social science research. Their main concern is that REBs will remain "dominated by members who have no specialized knowledge of the practices in a particular discipline can undermine the integrity of ethics review and, all too often, make it a process to be undertaken and survived instead of a discussion to be welcomed." To remedy this, they suggest that institutions be encouraged to establish multiple REBs with expertise in particular areas. They also make a number of suggestions for smaller reforms.
While Palys and Lowman have a number of significant concerns, it's worth noting that their comments on this draft are generally much warmer than their critique of the 2008 draft. This confirms my sense that while the latest TCPS has serious flaws, it is the best effort yet to include the concerns of social scientists into a general research ethics document.
Since today is the deadline for comments, I submitted an addendum to my February 6 comments:
To the Panel on Research Ethics,
On February 6 I submitted comments on the Revised Draft 2nd Edition of the TCPS (December 2009). I would like to amplify those comments slightly.
In my earlier comments, I noted my concern with Chapter 5's language warning about the possible stigmatization of groups. As I stated, I believe that this should not be the basis for restricting research in the social sciences and humanities.
Since then, I have reread the report, and I came across the following language in chapter 1:
The welfare of groups can also be affected by research. Groups may benefit from the knowledge gained from the research, but they may also suffer from stigmatization, discrimination or damage to reputation. Engagement during the design process with groups whose welfare may be affected by the research can help to clarify the potential impact of the research and indicate where any negative impact on welfare can be minimized. Researchers must also consider the risks and potential benefits of their research and the knowledge it might generate for the welfare of society as a whole. Where research on individuals may affect the welfare of a group(s), the weight given to the group’s welfare will depend on the nature of the research being undertaken and the individuals or group in question. This consideration does not imply, however, that the welfare of a group should be given priority over the welfare of individuals.
Again, let me emphasize that legitimate, critical research in the social sciences and humanities often is damaging to groups. As Edward Shils noted in 1973, "Any factual description, however objective and true, might be offensive to those who are sensitive and whose actions and qualities are such as to fall short of reasonable standards." I therefore do not consider the passage on group harms to reflect "core principles [that] transcend disciplinary boundaries and therefore, are relevant to the full range of research covered by this Policy."