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exemptions? Clearly <strong>in</strong> terms of a basic pr<strong>in</strong>ciple you do<br />

not want the person who is perform<strong>in</strong>g the research, him or<br />

herself, to be decid<strong>in</strong>g that the research is exempt so<br />

there has to be some level of review. Who does the review?<br />

How much paperwork? Do you need to assist them? Do you<br />

build <strong>in</strong> an <strong>in</strong>centive for a much larger system of for<br />

profit IRB's? Do you build an <strong>in</strong>centive for a system where<br />

you have prist<strong>in</strong>e paperwork and you have lots of people<br />

complet<strong>in</strong>g paperwork and review<strong>in</strong>g th<strong>in</strong>gs and fill<strong>in</strong>g out<br />

forms? And the very serious ethical issues sort of get<br />

lost <strong>in</strong> shuffle because you have diluted the effort so<br />

much.<br />

Do you have this -- I mean, I could imag<strong>in</strong>e<br />

develop<strong>in</strong>g an immaculate extensive system of paperwork that<br />

had no mean<strong>in</strong>gful ethical review <strong>in</strong> it. I have seen IRB's<br />

function that were very, very good at the paperwork but<br />

spent no time talk<strong>in</strong>g about what I th<strong>in</strong>k are the issues<br />

that an IRB ought to grapple with.<br />

So the question is would expansion divert<br />

valuable resources and valuable energy and how do you avoid<br />

that outcome? The danger is creat<strong>in</strong>g a burdensome possibly<br />

profit driven rubber stamp<strong>in</strong>g system dilut<strong>in</strong>g attention to<br />

the serious ethical issues.<br />

I could go on about the problems that I ran

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