Regulation of Experiments

Through his control of National Institute of Health grants, the Surgeon General is forcing the establishment of unnecessary boards to review all medical and behavioral experiments involving humans. Although his action is designed simply to control potentially dangerous research, such as research on LSD, it will have far-reaching and unfortunate consequences.

The Surgeon General may have been unaware of the possible ramifications of his directives, for the result of his action will be to inhibit the conduct of routine educational experiments.

Because he fails to make a clear distinction between regulation of medical research and regulation of behavioral studies, the Surgeon General places an unnecessary administrative burden on behavioral scientists. Medical experiments require scrupulous control, but it is not obvious that behavioral experiments need comparable regulation. There are many innocuous personality tests and psychological questionnaires which a Soc Rel graduate student must and should learn to administer and interpret. These hardly require intensive supervision.

Yet to fulfill the requirements set by the Surgeon General, the entire executive board of Harvard's Committee on Research Responsibility at the William James Center for the Behavioral Sciences would have to convene to review every research request of every graduate student receiving NIH funds. The executive board would be required to keep records to show that it had approved each research proposal, and, in addition, it would be obliged to make periodic inspections of each experiment to guard against any violations.

Carrying out these bureaucratic responsibilities would certainly delay approval for many experiments and might discourage some students from applying at all.

Harvard, however, already has a system of surveillance, in operation since 1963, which appears to be an effective alternative to the Surgeon General's approach. At Harvard, the Committee on Research Responsibility convenes only to discuss experiments of a potentially dangerous nature -- involving drugs, electric shock, sleep deprivation, etc. -- and not those that are patently harmless. The administrative official of the Committee screens all proposals, referring to the full board only those which require its attention. The others are approved automatically. This accelerates the entire process and saves the members of the executive board undue administrative work.

The approach used at Harvard during the last three years avoids the pitfalls of the Surgeon General's scheme, and should be the model for procedures across the nation.

There undoubtedly have been abuses of the privilege of experimentation in both the medical and behavioral sciences, and they will continue in isolated instances. It is the duty of the Surgeon General to insure that government funds do not finance such abuses, but this does not necessitate requirements so inflexible that certain forms of legitimate experimentation become impossible.

The Surgeon General asks that the explicit consent of the subject be given in all human experiments. He perhaps does not realize that this would invalidate a number of psychological tests. If an experimenter asks a subject for permission to deceive his sense of perception, the subject will go into the experiment looking for the trick. This obviously distorts his normal reactions and makes his observations worthless. Explicit consent is essential only for potentially dangerous experiments.

Some controls are certainly necessary, for governmental indifference to the problems of human experimentation would be lamentable. But over-zealous application of rigid regulations is equally inexcusable.