The stated purpose of issuing this ANPRM is to make the process of human subjects protection more efficient. We fully recognize the potential benefits of accomplishing this goal. But we also want to note that efficiency itself is not a moral imperative or even an ethical value; human subjects protection should not be compromised by a desire for increased efficiency, a view we believe OHRP shares.
Is there no ethical problem when bright, curious undergraduates are forbidden from seeking answers to their questions? When a researcher abandons a project after months of inaction by the IRB? Or finds that by the time she gets approval, she has missed the chance to do her research? When IRB inefficiency delays medical research that can save lives?
I had thought that PRIM&R recognized justice as an ethical value. And justice delayed is justice denied.