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NIH Regulatory Burden - Appendix 2
Research Community Workgroups Workgroups composed of representatives of the research community were formed to identify instances of regulatory burden of concern to them in a structured manner. Several research professional organizations assisted in identifying a broad spectrum of potential participants for these professionally facilitated workgroups. Participating in the effort to identify potential members were Applied Research Ethics National Association (ARENA), the Association of American Medical Colleges (AAMC), the Association of American Universities (AAU), the Association of Independent Research Institutions (AIRI), the Council on Governmental Relations (COGR), the Federal Demonstration Partnership (FDP), the Federation of American Societies for Experimental Biology (FASEB), the Government-University-Industry Research Roundtable (GUIRR), and Public Responsibility in Medicine and Research (PRIM&R). With the assistance of these organizations a workgroup was formed for each of the five subject areas, with the exception of Human Subjects Protections. In that case, two workgroups were formed. One was formed with representatives from institutions that perform a mid-to-high volume of human subjects research; another, with representatives from institutions performing a low-to-mid volume. Two were formed because there is some evidence that institutions’ Institutional Review Boards may be organized and operated differently, depending on the numbers of protocols that must be reviewed. Each workgroup was composed of approximately 10 members of the research community. In forming each, care was taken to include both active researchers as well as officials having institutional responsibility for the enforcement of Federal regulations. This diversity is necessary to capture the perspective both of those performing the research and those charged with developing, implementing and overseeing the administration of these regulatory programs. The day-long agenda for each workgroup was the same. This format had been established, in advance, by a Planning Workgroup composed of one or two members from each subject-specific workgroup to assure that a common approach was followed. Each workgroup was professionally facilitated and was asked, at the outset, to identify the objectives and the protections that the system of regulation should accomplish if it is to be successful. Then, within the overall context of these objectives and protections, they were asked to identify potential aspects of the regulatory process that could be streamlined. Once these items were identified, workgroup members were asked to identify potential solutions to the issues. About mid-way through the day, the members met with key officials who administer the specific regulations under review, to better understand the Federal perspective, and to explore opportunities for change with them. The regulations under examination are administered by multiple Federal agencies. While the specific request came from the Appropriations Subcommittee that oversees the activities of NIH and most of the agencies of its parent organization, DHHS, it was not always possible to assess the regulatory burden of the NIH/DHHS regulations without assessing the regulations of the other agencies involved because of the considerable overlap. In those cases, the workgroup was asked to identify specific aspects of this larger set of regulatory programs that could be made more efficient and to propose solutions for the issues that were identified. For the purpose of this effort, regulatory burden was defined as any aspect of the Federal legislation, regulation, or policy, or Federal/research institution practices that could be made more efficient without diminishing the intended level of protections. This definition recognizes that regulatory burden may arise from a variety of sources. It may be the result of restrictive Federal legislation, regulations, policies or practices that ultimately force requirements considered to be burdensome by the research community. An additional level of complexity is added when there are conflicting legislation, regulations, or policies administered by multiple Federal agencies, by Federal and State agencies, or by different components within the same agency. Burden also may result from ineffective or inefficient practices by the research institution in administering the system of regulation imposed by Federal organizations. Finally, it should be noted that the purpose of the workgroups was not necessarily to come to consensus. While there was general agreement on the issues and the proposed solutions, there was not necessarily unanimity on each. The issues and solutions identified by each of the workgroups, is presented as sections III through VII of this Report. The membership of each group follows in this Appendix. The members of the Planning Workgroup merit special recognition and they are denoted on the listings. Conflict of Interest - Workgroup Participants
Donald Baldwin
Gary Isom
Joyce Jentoft *
Russ Lea
Anthony Merritt
Barbara Siegel
Sharon Sumpter
Delia Talamentez
Frederic Y. M. Wan
* Denotes member of Planning Workgroup. Research Integrity - Workgroup Participants
Mark Brenner *
David Kauffman
Ronald S. Newbower
Julie Norris
Robert Rich *
Garrett Sanders
S. Andrew Schaffer
* Denotes member of Planning Workgroup. Human Subjects Protection - Workgroup Participants (Mid to High-Volume Institutions)Richard Atkinson
Gary Chadwick *
Barbara Echols
R. Peter Iafrate
Philip Ludbrook
Helen McGough
Judith Nowack *
Gwenn S. F. Oki
Lucille Pearson
Ada Sue Selwitz
* Denotes member of Planning Workgroup. Human Subjects Protections - Workgroup Participants (Low to Mid-Volume Institutions)Warren K. Ashe *
Jeffrey M. Cohen *
Ed Conradi
Louise Griffin
Karen Hansen
Susan Kornetsky
Robert M. Nelson
Gabriel Radvansky
Ardis Savory
* Denotes member of Planning Workgroup. Animal Care and Use - Workgroup ParticipantsTed Cicero *
Ralph Dell
Melvin Dennis
Molly Greene *
J.R. Haywood
Tanise L. Jackson
Marky Pitts
Steven Schiffer
Walter M. St.-John
John L VandeBerg
* Denotes member of Planning Workgroup.
Hazardous Waste Disposal - Workgroup ParticipantsBruce Backus
Stephen Benedict
Janet Greger *
Brian Hales
Suzanne Howard
Gordon Kaye
David Rainer *
David Silberman
Karen VanDusen
* Denotes member of Planning Workgroup.
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