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exam<strong>in</strong>ations. The Food and Drug Adm<strong>in</strong>istration by contrast<br />

does go out and at least go through a paper trail at<br />

<strong>in</strong>stitutions. The OPRR, NIH and the other agencies do not.<br />

OPRR has a large case load and depends on<br />

outside expertise to -- for most of the scientific<br />

evaluation of the cases that are brought to its attention<br />

and it has difficulty carry<strong>in</strong>g out major <strong>in</strong>vestigations.<br />

Dr. McCarthy talked not only about the backlog <strong>in</strong><br />

<strong>in</strong>vestigations but also the impediments that it has to act<br />

like an <strong>in</strong>vestigatory office.<br />

(Slide.)<br />

To sum up then, the problems revealed by<br />

history are first that the Department of HEW and the other<br />

agencies or HHS now that sponsors science see research as<br />

the primary mission and address human subjects protection<br />

only when pushed, usually follow<strong>in</strong>g a crisis of some sort.<br />

Secondly, that no federal agency holds the<br />

position of an authority to ensure the adequacy and<br />

uniformity of human subjects protection. Indeed, no one<br />

knows how much human subjects research is now ongo<strong>in</strong>g with<br />

federal sponsorship much less beyond federal sponsorship.<br />

The Office for Protection from Research Risks<br />

that NIH has the <strong>in</strong>formal role of first among equals among<br />

the offices and the different agencies, it has by far the

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