In September 2010, OHRP posted drafts of new FWA form and FWA Terms of Assurance. In my comments, I asked that the drafts be revised to make clear that under 45 CFR 46.103(b)(1), institutions have the right to choose any statement of principles they wish, including statements they formulate themselves. Other comments also made this point.
I also asked that the FWA terms allow institutions to conform to the current version of Canada's Tri-Council Policy Statement, rather than the 2005 version mentioned in the OHRP draft.
OHRP has now released the new version of the FWA terms. I am happy to report that both of my suggestions have been adopted.