Wednesday, November 10, 2010

Comments: FWA Forms Should Reflect Common Rule

On October 4, I reported that OHRP was inviting comments on drafts of new FWA form and FWA Terms of Assurance.

Prior to the October 25 deadline, OHRP received comments from only five individuals and two professional organizations, all of which are posted at

Of these seven comments, three (including mine, of course) complained that the draft Terms of Assurance, like the existing ones, violate the Common Rule's pledge that an institution's statement of principles "may include an appropriate existing code, declaration, or statement of ethical principles, or a statement formulated by the institution itself."

No one made a case for retaining the discrepancy between the regulations and the forms.

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