I think there is value in having the department chair sign protocols if that is the institution's policy. The faculty member definitely broke the rules in this situation and should be reprimanded in some way. I agree with Bill's suggestion about conditional approval based on the department chair's ok. As well as a reprimanding letter to the faculty member copied to the dean and/or provost. The faculty member should be marked but shouldn't have to feel it forever (in this case). Or you could force the faculty member to do a presentation on ethical procedures in human subject research for his/her class, the department, or school.....possibilities are endless here. Humiliation is a powerful motivator. Below is the process for IRB protocols at my institution: We used to have the department sign off on faculty protocols, but the IRB decided to remove that requirement. It is required at our institution for all human subject research projects (faculty and student) to seek IRB approval, not just the protocols with sponsored support. All student protocols are required to have a faculty sponsor's signature. The department chair is one of the people that signs off on the internal grant approval form. So if a faculty member has sponsored support and is conducting human subject research, the department chair has already signed off on the grant proposal. Heather Dragoo Sponsored Research Office University of Southern Indiana 8600 University Blvd. Evansville, IN 47712 (812) 465-1126 xxxxxx@usi.edu http://www.usi.edu/gr&res/ogsr.asp -----Original Message----- From: Stephen Erickson [mailto:xxxxxx@BC.EDU] Sent: Thursday, November 13, 2003 9:41 AM To: xxxxxx@HRINET.ORG Subject: Re: [RESADM-L] Forged Signature on IRB Application I consur with others who have said this act of forgery cannot be ignored. I don't know what your internal procedures are so it's difficult to recommend specific actions. It seems to me that it's a hard to make an ethical argument that some forgry is ok. I would like to add another question to the discussion. If this act of forgery were to be passed off as not being important enough toworry about, then I think we have to ask what added value is there in having the Department Chair sign the protocols. Personally, I think there is significant value added, but others may disagree. For those who think there is value in a Chair signing, this act of forgery has both ethical and practical implications. The Chair has a right to know that his/her signature has been forged --- and he/she has a responsibility to take disciplinary action against the forger. I'm not sure Spanky's solution of decapitation is a punishment that fits the crime -- but if the Chair is aching to use a guillotine, so be it. Stephen Erickson, Director Office for Research Compliance and Intellectual Property Management Boston College, LCOB 550 Chestnut Hill, MA 02467 Telephone: 617-552-3345 Office Fax: 617-552-6981 Fax to my computer: 413-895-8328 -----Original Message----- From: Research Administration List [mailto:xxxxxx@HRINET.ORG] On Behalf Of Barbara Gray Sent: Wednesday, November 12, 2003 11:31 AM To: xxxxxx@HRINET.ORG Subject: [RESADM-L] Forged Signature on IRB Application Compliance/IRB staffers out there, how would you deal with this situation? We require department chairs to sign off on human subject applications. A faculty member is in a rush to have an human subject protocol approved (under expedited criteria) for a very innocuous procedure--virtually no risk at all except it is a phyical measurement that does not fit within exemption criteria. (Note that the project involves students who will be collecting the data as part of a class assignment.) She indicates she'll just sign for her chair, we indicate that she can't do that, and, lo and behold, the signature page comes in a couple of days later with the chair's signature forged. Would you take this to her chair? Her dean? The provost? Would you prohibit her from implementing the protocol (which will impact the students in her class)? Would you bar her from doing human subject research for a period of time? Is this "misconduct" that should be referred for handling through ORI regs? (note that we've made our misconduct policy applicable to all research and scholarship, not just that funded externally or by the Feds.) Personally, I find the faculty member's action offensive and unethical (if not downright illegal)--if she will do this on an application, might she do the same someday on a consent form?? But, in the big scheme of things, is this worth going to the mat on? After all, it's only falsification of an internal signature, not scientific data.... Thanks. -- ================================================================== Barbara H. Gray, Director Office of Research & Grants Administration College of Charleston 66 George Street Charleston, SC 29424 Campus Location: 407-G Bell Bldg. Office: 843.953.5673 Desk: 843.953.5885 Fax: 843.953.6577 e-mail: xxxxxx@cofc.edu URL: http://www.orga.cofc.edu/ ================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ======================================================================
