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291 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 to take out of the next number of patients that he has the fillings on the theory that he is conducting a form of research. Does he know it is research? Maybe and maybe not. Some legal services clinics. On my campus we have some very interesting examinations going on in our clinic at our law school about when are you actually conducting research. When you are taking students, you videotape them, you teach them how to interview clients, the clients give their consent for the interview, but then you go on, you train other students with it, and then you start doing research on how do you generalize this knowledge about this sort of interviewing and how do you use these. Pretty interesting questions that they are exploring. Some corporate and industrial health safety and fitness programs and some developers of genetic tests. So my current thinking is that rather than taking the global approach with all the practical problems that entails it would be superior to start with the known problems, add them in, take a cautious incremental approach where you can document the cost/benefit ratio, that official cost/benefit ratio of adding in some regulatory system rather than taking a sweeping approach.

292 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 I think that you have to focus on the goals of protecting subjects from risk, the unwitting participation aspects, and again on the focus of informed consent an independent review where you know that there is a danger of risk. So then the question is how do you reach that within the available resources consistent with reality. The paradigm that I think is applicable that I use in thinking about a lot of the problems that I deal with is one that was first introduced -- actually I heard Bud Relman give a presentation probably 15 years ago and he used the term "low incidence, high severity problem." The serious problems do not occur very often. When they do occur they are very, very serious. So what is the low incidence, high severity problem of this nature? What sort of response does it suggest? To my thinking of low incidence, high severity problem the most sensible approach is that you put almost all of your resources into education. Most people most of the time want to do the right thing and you have to make sure you know what it is. We do not have adequate resources in our system for that right now. The second thing you have to do after education

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I th<strong>in</strong>k that you have to focus on the goals of<br />

protect<strong>in</strong>g subjects from risk, the unwitt<strong>in</strong>g participation<br />

aspects, and aga<strong>in</strong> on the focus of <strong>in</strong>formed consent an<br />

<strong>in</strong>dependent review where you know that there is a danger of<br />

risk.<br />

So then the question is how do you reach that<br />

with<strong>in</strong> the available resources consistent with reality.<br />

The paradigm that I th<strong>in</strong>k is applicable that I use <strong>in</strong><br />

th<strong>in</strong>k<strong>in</strong>g about a lot of the problems that I deal with is<br />

one that was first <strong>in</strong>troduced -- actually I heard Bud<br />

Relman give a presentation probably 15 years ago and he<br />

used the term "low <strong>in</strong>cidence, high severity problem."<br />

The serious problems do not occur very often.<br />

When they do occur they are very, very serious.<br />

So what is the low <strong>in</strong>cidence, high severity<br />

problem of this nature? What sort of response does it<br />

suggest?<br />

To my th<strong>in</strong>k<strong>in</strong>g of low <strong>in</strong>cidence, high severity<br />

problem the most sensible approach is that you put almost<br />

all of your resources <strong>in</strong>to education. Most people most of<br />

the time want to do the right th<strong>in</strong>g and you have to make<br />

sure you know what it is. We do not have adequate<br />

resources <strong>in</strong> our system for that right now.<br />

The second th<strong>in</strong>g you have to do after education

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