No need to go! Workplace studies and the resources of the revisedNational Statement

Monash Bioethics Review Vol. 26 No.3

RESPONSE37 Ethics Committee Supplement

No need to go! Workplace studiesand the resources of the revisedNational StatementCHRISTOPHER CORDNER

SchoQI of PhilosophyUniversity of Melbourne

COLIN THOMSON

Professorial FellowFaculty of LawUniversity of WollongongChairAustralian Health Ethics Committee

ABSTRACT

In their article (Unintended consequences of human research ethicscommittees: au revoir workplace studies?', Greg Bamber andJennifer Sappey set out some real obstacles in the practices andattitudes of some Human Research Ethics Committees (HRECs), toresearch in the social sciences and particularly in industrialsociology. They sheet home these attitudes and practices to the wayin which various statements in the NHMRC's National Statement[1999] are implemented, which they say is often (in conflict with animportant stream of industrial sociological research' in Australia.They do not discuss the recently completed revision of the NS. Weundertake to show that the revised National Statement meets theirconcerns about research in industrial sociology, and to drawattention to the resources of the revised National Statement thatengage with those concerns. A more general aim is to display thegreater scope, in the revised National Statement, for researchers toshow to HRECs that their research is justified by virtue of itsreflecting the established methodology and traditions of theirdiscipline. The revised National Statement, we suggest, provides fora more flexible and responsive approach than its predecessor to theethical review of many areas of research.

IntroductionIn their article 'Unintended consequences of human research

ethics committees: au revoir workplace studies?' (Monash BioethicsReview, current issue), Greg Bamber and Jennifer Sappey have set outsome real obstacles, in the practices and attitudes of some HumanResearch Ethics Committees (HRECs), to research in the socialsciences and particularly in industrial sociology. They sheet homethese attitudes and practices to the way in which various statements inthe NHMRC's National Statement [19991) are implemented, which they

Monash Bioethics Review Vol. 26 No.3 38 Ethics Committee Supplement

'try(ing) to apply anparadigm and.. .not

conditions under which

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say is often 'in conflict with an important stream of industrialsociological research' in Australia. They also write: 'Perhaps anunanticipated consequence of the National Statement is that it inducedsocial scientists to be 'servants of power' to an even greater extent thanthey were in the first half of the 20th century'.

The authors do not discuss the revised NS at all in their article,as the final version had not been released at the time of their article.They observe only that it 'prom ises to be more suitable for socialscientific research than the 1999 version', with which HRECs havebeen working for the past eight years.

The authors identify three main criticisms of the 1999 NS thatare made by researchers:

1. It has induced 'ethics creep', ie processes of ethical reviewhave become 'unwieldy, intrusive and excessivelydemanding';It has contributed to HRECs 'bas(ing) their decision-makingon their own interpretations of "amorphously expressedstandards'" in the NS;It has contributed to HRECsinappropriate medical-researchempathis(ing) sufficiently with thesocial scientists operate'.

The authors focus these criticisms by reference to research proposalsin the field of industrial sociology. Key issues that arise in theirdiscussion are:

1. The definition of who are participants in research;2. The meaning of harm in research, and the consequences of

both participants and researchers being at risk;The use of covert research methods;The apparent privileging of individual rights of participantsover the benefits of research;The inconsistency in interpretation of the NS amonginstitutions

In this article we want to engage with these important criticismsand issues . We accept most of what Bamber and Sappey say, but wealso believe that in the revised NS most of the authors' concerns havebeen met. Our immediate aim is therefore to draw attention to theresources in the revised NS that engage with those concerns. Moregenerally, we think the revised NS provides for a more flexible andresponsive approach than its predecessor to the ethical review of manyareas of research. We therefore also hope this article will help orientpotential users of the NS to some of the broader resources of the newdocument.

Revision of the 1999 National StatementA key feature of the 1999 NS was its declared extension, for the

first time, to all human research. Since previous versions of theNHMRC research guidelines had referred only to health and medicalresearch (though it had, since 1985, often been applied in the ethical


review of other research) it is not surprising that the NS still reflectedthe 'medical-research paradigm' mentioned by Bamber and Sappey.Nor is it surprising that the deliberations of HRECs accustomed tousing the NS should also reflect this paradigm. A main aim of therevised NS is to make it responsive to the real differences in kinds anddomains of human research.

We believe the aim of bringing the ethical review of all humanresearch under the NS was a desirable one. The recent process ofrevising the NS brought to the surface the difficulties in achieving thisaim, difficulties which are a source of the issues raised by Bamber andSappey. In the revision we sought to resolve these difficulties in twobroad ways: first, through attention to various aspects of the context inwhich ethical review takes place. We undertook to give the processes ofethical review a looser, more flexible structure that makes them moreresponsive to the needs of different areas and forms of research; weclarified the difference between the statement of general ethicalprinciples and their application; and we made provision for reviewbodies to draw on wider resources for ethical review. Our second way ofresponding to the sorts of issues raised by Bamber and Sappey was byrevising a good deal of the content of the ethical guidance in the NS.(We were of course guided throughout by the submissions we receivedin two rounds of public consultation on draft revisions of the NS.) Inthis article we deal with these two broad approaches in turn.

The context of ethical review

Flexible, responsive processesThe revised NS explicitly authorises institutions to consider

setting up processes of review other than by HREC - less demandingreview for research with less risk, and also review that is betterinformed about and more responsive to different areas of research. Thismight be , for example, review at a department level, where those whoare best acquainted with the methods and the risks of the specificresearch can be involved in its ethical review. (It is of course importantthat the review process not become either mere 'rubber-stamping' bythe researcher's colleagues or a mask for disciplinary censorship; andthe revised NS says a good deal in Section 5 about how institutionsshould approach getting these balances right.) In addition, the revisedNS has tightened up the requirement on HRECs to have sufficientexpertise in the areas of research it has to review, and has emphasisedthe importance of good communication with researchers before, duringand after ethical review. It is intended that decisions be arrived at onthe basis of the best possible understanding of the issues at stake.If these various opportunities and responsibilities are taken up byinstitutions many of the causes of 'unwieldy' or 'excessively demanding'ethical review should dissolve.

Principles and applicationThe revised NS is much longer than its predecessor, by virtue

both of its broader content and of the detail of its application. But we

Monash Bioethi cs Review Vol. 26 No.3 40 Ethics Committee Supplement

were aware that even a much-extended document could not offerguidance on ethical issues specific to each arena of human research,and that it would be a mistake for it to try to do so. We were aware thatthere will very often be a gap between what guidance the Statementdoes offer, and specific issues of concern to researchers .

We responded to this difficulty in two ways. First, we adopted astructure that emphasises the difference between the statement ofethical principles and their application. In most chapters of the revisedNS addressing types of human research or categories of humanparticipants, we sought to show that specific paragraphs were in factapplications of the general principles set out in the opening chapter.Using the names of those basic principles as sub-headings remindsreaders and users of the revised NS that more specific guidance isusually an application of a principle . In this way, we have sought toreduce errant interpretations of generally expressed principles.

Drawing on wider resources for reviewSecondly, we were especially aware of concerns along these lines

among social scientists. That led to the following paragraph in the'User's Guide' at the front of the revised NS:

This National Statement does not exhaust the ethical discussionof human research. Even a single research field covers amultitude of different situations about which the NationalStatement will not always offer specific guidance, or to which itsapplication may be uncertain. Where other guidelines and codesof practice in particular research fields are consistent with theNational Statement, researchers and members of ethical reviewbodies should draw on them when necessary to clarifyresearchers' ethical obligations in particular contexts.This is a very important paragraph in the revised NS. Its

importance is highlighted by its repetition in the Introduction toSection 3: 'Ethical considerations specific to research methods orfields', and again in the Introduction to Section 4: 'Ethicalconsiderations specific to participants'. It is also partly repeated andexpanded on, as follows, in the final part of Section 1: 'Values andprinciples of ethical conduct':

Research, like everyday life, often generates ethical dilemmas inwhich it may be impossible to find agreement on what is right orwrong. In such circumstances, it is important that all thoseinvolved in research and its review bring a heightened ethicalawareness to their thinking and decision-making. The NationalStatement is intended to contribute to the development of suchawareness .

This National Statement does not exhaust the ethicaldiscussion of human research. There are, for example, manyother specialised ethical guidelines and codes of practice forspecific areas of research. Where these are consistent with thisNational Statement, they should be used to supplement it whenthis is necessary for the ethical review of a research proposal.


These ethical guidelines are not simply a set of rules. Theirapplication should not be mechanical. It always requires, fromeach individual, deliberation on the values and principles,exercise of judgement, and an appreciation of context.Even given the clarification of principles in the revised NS and the

further explanation of how they apply, these important paragraphsrecognise the limitations on the capacity of a single document toprovide specific and explicit ethical guidance on each issue in everyhuman research project. The paragraphs impose a responsibility onthose reviewing research to draw on specialised guidance elsewhere. Ifthis responsibility is shouldered, that should counter any tendency fordecisions of ethical review to reflect an 'inappropriate medical-researchparadigm', and encourage a responsiveness to 'the conditions underwhich social scientists operate'.

Revision of ethical contentThe revised NS thus encourages greater flexibility, and greater

responsiveness to the variety of human research, both in institutionalprocesses of ethical review and also in the range of materials(guidelines and codes of conduct) that are drawn on in the ethicalreview of research.

The paragraph quoted above requires that any other guidelinesdrawn on must be 'consistent with' the revised NS. This means ofcourse that such guidelines can be of help with the issues Bamber andSappey raise only if the revised NS does not itself obstruct the kind ofresearch they want to preserve. For if the NS excluded such research,the 'consis ten cy ' requirement would also exclude all guidelines thatpermitted it . In addition to the changes already described, the specificcontent of the revised NS does indeed give much greater scope than didthe 1999 NS to the kind of research Bamber and Sappey discuss. Tohelp show this, we now engage more closely with their discussion(Doing this will also indicate the kind of circumstance in whichguidelines or codes of practice beyond the NS should be drawn on.)

Participation and consentThe authors write that for workplace studies some HRECs require

the consent of 'all participants', generally including the consent of 'topmanagement'. 'It is unlikely that managerial consent will be grantedunless there is benefit guaranteed and top management's "truth"assured, and it is unlikely that HREC consent will be granted unlessthere is managerial consent'. They note the constraining effect of thisrequirement on workplace research, and say that the requirement 'failsto understand the conditions under which industrial sociologistsoperate'.

Three distinguishable elements of the 1999 NS give rise to thisconcern. First, the 1999 NS defines 'participants' very widely, toinclude 'those upon whom the research impacts' and says that 'th econsent of the participants must be obtained'. Since research may wellimpact on management even if they are not involved in the research


itself, it is easy to why some HRECs would standardly require theconsent of those in management for workplace research. If that consentis strictly speaking consent only to their own 'participation' in theresearch, it does not by itself give management right of veto overworkplace research. But if those in management are not in fact going tobe involved in the research itself, yet the NS implies that they are stillparticipants and their consent is therefore needed, it is hard to seewhat purpose their consent could be sought for other than that ofgiving approval for the study. So even if treating managers asparticipants simply because they may be affected by the research doesnot strictly give them right of veto over the research, in practice it maywell go a long way towards doing that.

A second element of the NS also very likely plays a role here.Bamber and Sappey say that 'The NS requires organisational approvalfor any workplace study', and presumably they have in mind thisparagraph of the .1999 NS:

In some circumstances and some communities , consent is notonly a matter of individual agreement, but involves other properlyinterested parties, such as formally constituted bodies of variouskinds, collectivities or community elders. In such cases theresearcher needs to obtain the consent of all properly interestedparties before beginning the research (paragraph 1.9).

This paragraph may not have been intended to apply to workplaceresearch, but it is not surprising if it has been interpreted as soapplying. The practice by some HRECs of requiring managerial consentfor a project to go ahead, even when the managers are themselvesoutside the research project, does seem to find support in thisparagraph.

The third element of the 1999 NS that supports this HRECpractice is, as Bamber and Sappey note, what it says about the'protection of participants'. If protection of the welfare of participants isto take precedence over everything else, then when the 'welfare' ofmanagement is threatened by workplace research, and managementautomatically count as participants, such research will very likely notbe approved.

We will comment on the changes to the NS in respect of each ofthese elements in turn. First, one important conceptual revision in therevised NS is not to include 'th ose upon whom the research impacts 'among 'participants'. (See 'What is human research?' under 'Purpose,scope and limits of this document' for a list of forms of participation inhuman research.) The effect of this is that management will not countas participants unless they are involved in the actual research in one ofthe ways described in the revised NS. In the sorts of research describedby Bamber and Sappey they will characteristically not be involved inthose ways; and the important upshot is that there is no standingrequirement that their consent be sought for the research.

The revised NS, of course, recognises that research can haveimplications for non-participants, and it offers two ethical bases fortaking account of non-participants . The first basis is the need to


'engage' with 'properly interested parties' other than participants, andthis is set out in our revision of paragraph 1.9 of the 1999 NS, quotedabove. The revised paragraph reads:

Within some communities , decisions about participation inresearch may involve not only individuals but also properlyinterested parties such as formally constituted bodies,institutions, families or community elders. Researchers need toengage with all properly interested parties in planning theresearch (paragraph 2.2.13) .

It might already be stretching things to apply this directly to workplaceresearch given that the context is now simply 'communities', notusually understood to include corporations or employers andemployees. But setting that aside, the second sentence - enjoiningresearchers to 'engage' with properly interested parties in the planningof their research - does not require the consent of those parties for theresearch. (The first sentence does not impose any such requirementeither, whether the 'may' is taken as a 'may of permission' or as a 'mayof possibility'.) The paragraph allows that in some cases people otherthan participants, with an 'interest' in the research, might be entitledto a say in 'decisions about participation'. It thus locates an issue fordebate, whose resolution will vary depending on the nature of theresearch and its specific circumstances. Clearly it would be open to asocial science researcher - wanting to explore employees' workplaceexperiences, for example - to argue that neither the CEO nor anyoneelse in management should have a say about others' participation inthat research. (Of course this approach might raise practical questionsabout how the research is to be carried out. We return to thispossibility in a moment.)

The second basis on which to take account of non-participants who may include management - is an assessment of the risks of theresearch and on whom they fall. The revised NS requires that 'risks ofharm to research participants, and to others, be assessed. Researchwill be ethically acceptable only if its potential benefits justify thoserisks' (Chapter 2.1, Introduction) . Even where those in management arenot participants, effects on them must be considered in the course ofdeciding whether the benefits of the research justify its risks Further,the kind of benefit to participants the authors mention - 'vulnerablepeople's rights for their story and "truth" to be heard' - could clearly bean important part of such a justification of research. That sort ofbenefit, by the way, while not described in precisely those terms in therevised NS, is reflected in the second sentence of this passage:

Respect for human beings is a recognition of their intrinsic value.In human research, this recognition includes abiding by thevalues of research merit and integrity, justice and beneficence.Respect also requires having due regard for the welfare, beliefs,perceptions, customs and cultural heritage, both individual andcollective, of those involved in research (paragraph 1.10).Evidently one reason for requiring managerial consent for

workplace research can be that management is seen as a gatekeeper to


physical access to a workplace. This is one important source of theissue of what Bamber and Sappey call 'covert' research, discussed inthe revised NS under the concepts of limited disclosure, concealmentand deception. There are in fact two issues here. The revised NS saysthat research involving concealment from or deception of participantsmay be carried out only if 'there is no known or likely reason forthinking that participants would not have consented if they had beenfully aware of what the research involved' (paragraph 2.3.2 c). But themain concern of Bamber and Sappey seems to be with the need forcovert research in order to sidestep gatekeepers who are not, under therevised NS, themselves research participants . The NS is silent on thequestion of deception of those whose consent may, as a practicalmatter, be needed for access to the workplace - unless they arethemselves participants in the research - beyond enjoining researchersto consider the effects on them as on anyone else affected by theresearch. It should be noted, however, that two obstacles in the 1999NS to the possibility of workplace research in such circumstances havedisappeared from the revised NS. Since there is no standingrequirement for the consent of those in management unless they aregenuinely participants in the research, nothing in the revised NSimplies that they are automatically ethically entitled to know about theresearch. Secondly, a point further discussed below, the revised NScarries no presumption that people, whether participants or not, areautomatically entitled to protection from the risk of bad effects uponthem of research. These points of course do not imply that covertresearch to 'get around' managers as gatekeepers is thereforeautomatically ethically justified. Rather, they show that the revised NSkeeps open the space for legitimate ethical argument seeking to justifysuch research. Clearly, this is one of the difficult issues whereguidelines specific to an area of research could be relevant to thedeliberations of an HREC or other review body.

Individual rights ofparticipants and the benefits of researchIn their conclusion, the authors describe, as the main issue

underlying the problems they identify, 'the extent to which, given aright to privacy, whether individual, collective, private or commercial,there is also a right to acquire knowledge '. They believe that the 1999NS wrongly privileges the 'right to privacy' over the latter right, throughits unqualified commitment to the protection of participants. The effectof this, in the domain that concerns the authors, is seriously tocompromise the capacity of research in industrial sociology to reveal'the realities and complexities of the social relations of production' andthereby to help uncover issues like 'sabotage, bullying, inequality,abuse, corruption and many other issues of human rights... ', Severalparagraphs in the 1999 NS lend weight to this concern. The Preamblesays that 'the primary purpose [of the NSj is the protection of thewelfare and the rights of participants in research'; paragraph 1.4 saysthat 'respect for the dignity and well-being of the participants takesprecedence over the expected benefits to knowledge'; and paragraph 1.6


says that 'in other [than clinical] research involving humans that isundertaken solely to contribute to knowledge, the absence of intendedbenefits to a participant should justly be balanced by the absence of allbut minimal risk'. It could perhaps be argued that this last paragraphdoes not apply to workplace research that aims to rectify injusticerather than 'solely to contribute to knowledge '. But - especially giventhe inclusion of management as 'participants' merely because theystand to be affected by the research - it would again not be surprisingif some HRECs read all these paragraphs as warranting the rejection ofresearch that risked 'harm' to managers through exposure of theirunjust behaviour.

We have already noted that the narrower definition ofparticipants in the revised NS reduces the present concern. Otherelements in the revised NS are relevant here too . Consider the questionof whether to approve a research project that might reveal that (say)middle management in a large firm had been bullying employees orotherwise treating them unjustly. The revised NS does not say, orimply, that those managers are entitled to protection against the effectson them of the exposure of their unjust behaviour. The relevantwording of the revised NS is this:

The purpose of this National Statement is to promote ethicallygood human research. Fulfillment of this purpose requires thatparticipants be accorded the respect and protection that is due tothem. It also involves the fostering of research that is of benefit tothe community ('Purpose, scope and limits of this document'[.

The phrase 'the respect and protection that is due to them' wascarefully chosen. It does not say that participants are entitled to'protection' against any risk of adverse effects on them from research. Itis helpful to think more broadly here . Being jailed for a crime he or shehas committed is evidently an 'adverse effect' on a person, but no-onethinks that people are in general entitled to protection against thatadverse effect on them of our legal system. What protection against theadverse effects of their deeds is 'due' to people depends in part on theethical and legal standing of what they have done; and the quotedpassage makes allowance for this. The passage quoted speaks of'participants', but the ethical idea informing it has more generalapplication. So if research in industrial sociology were to carry a risk ofadverse effects ('harm1 on say an employer because of his or herunfairness to employees, protection from this harm may well not be'due' to him or her, whether or not s /he was a participant in theresearch.

Another passage from the revised NS bears on this point:'(Respect) involves providing for the protection of those with diminishedor no autonomy, as well as empowering them where possible andprotecting and helping people wherever it would be wrong not to do so'(Section 1: Introduction). Here, too, the revised NS deliberately placesits statements about the protection of participants in a broader contextof justice. It is not a question of 'protecting participants' (or others)come what may, but of protection where this is due, and where it would


be wrong not to provide it . The revised NS thus does not privilege theright to privacy over the right to knowledge so as to exclude researchthat uncovers 'sabotage, bullying, inequality' etc in the workplace. Onthe contrary, it makes space for researchers to argue that thoseresponsible for (say) bullying in the workplace are not owed protectionagainst exposure of their bullying.

A closely related point is that the revised NS no longer speaks ofresearch having to strike a 'balance' between risks and benefits, butalways of risks having to be justified' by potential benefits of theresearch. The concept of 'balance' implies a quantitative relation: thequantity or number of the research risks of harm must be 'outweighed'by the potential benefits. That in tum implies that any harm or adverseeffect - even the adverse effect on a bully of having his bullying exposed.: necessarily counts against the research, even if it might finally be'outweighed' by the research benefits. The concept of the researchbenefits having to justify' the risks does not carry this implication. Aparticular 'harm' resulting from research might have no ethical weighttelling against research. The 'harm', to someone in management,described in the previous paragraph - harm resulting solely from his orher own unjust behaviour - might well fall into this category.

Some other issues

Withdrawing dataBamber and Sappey have a further specific concern here though.

They object to the effects of the requirement that 'a participant must befree at any time to withdraw consent to further involvement in theresearch at any time' (paragraph 1.12). Their concern is that if theresearch is not acceptable to participants when the purpose of theresearch is in due course disclosed to them, 'this may leave researchersin a chasm of their own, never confident that the data can be finalisedand secured if any party has the option of withdrawing its pertinentdata from the study'. Here we simply note that the revised NSmaintains the entitlement of participants to withdraw their data, andthat this should be of less concern when the revised NS's distinctionbetween participants and others affected by the research isappreciated. The fact that information about third parties - for examplemanagement - may come to light through what participants say doesnot make those third parties participants, and there is nothing in therevised NS to suggest that those parties automatically have authority toblock research use of such information about themselves. (Privacyconsiderations at law will still of course apply.)

Written consentThe authors several times mention that some HRECs insist on

written consent from participants for all research, and that anunintended consequence of this insistence 'may be that the integrity ofthe research [in industrial sociology] is compromised'. We note that the1999 NS does not insist on written consent, and that this HREC


insistence appears to be a function of broader influences. The revisedNS, however, is more emphatic about the range of modes in which,depending on various factors, consent might best be given. It does noteven implicitly privilege written consent.

Inconsistency between HRECsThe responsibility of reviewers to draw on research-specific

guidelines where the revised NS does not offer specific guidance or hasuncertain application should also help limit inconsistency betweenHRECs - another justified concern of the authors. Of course, as therevised NS also says, human research 'often generates ethicaldilemmas in which it may be impossible to find agreement on what isright or wrong.' About ethical issues, people who are well-informed,thoughtful and of good will can sometimes differ in their views.Differences between HRECs are sometimes differences of this kind,rather than of mere inconsistency.

Communication between researchers and HRECsNear the end of their article Bamber and Sappey write:Could HRECs display a greater degree of trust in well-qualifiedresearchers? This is already the case in some institutions. But inothers, researchers have told us that the HREC regimes appear todisplay a low degree of trust in well-qualified researchers , whichhas the unfortunate tendency to foster an adversarialatmosphere. Enforced compliance does not necessarily lead tounderstanding. We suggest that there should be, betweenresearchers and HRECs, open and constructive discourse....

We agree. The importance of 'open communication' between reviewbodies and researchers is highlighted in the revised NS (see especiallyparagraphs 5.2 .13 and 5.2 .14) . The review process 'should not beadversarial', but should reflect a 'shared commitment' on the part ofreviewers and researchers to generating ethically good research. 'Trustin well-qualified researchers' is an important element of this sharedcommitment that is fostered by open discussion. The requirement,emphasised earlier, that review bodies be ready to draw on researchspecific guidelines reflects the same ideal. This is not, of course, amatter of 'anything goes'. The Preamble of the revised NS says thathuman research 'often involves public interaction between people thatserves a public good', and that this gives rise to a 'pu blic responsibilityfor seeing that these interactions are ethically acceptable to theAustralian community'. That responsibility is 'acknowledged and giveneffect in the wide-reaching authority of the National Statement'.

ConclusionWe have tried to highlight some of the resources the revised NS

provides for responding to the issues Bamber and Sappey have raisedabout the ethical review of social science research. More generally, ourdiscussion has aimed to display the greater scope, in the revised NS,for researchers to show to HRECs that their research is justified by


virtue of its reflecting the established methodology and traditions oftheir discipline. In doing this we intend no disrespect to the authors ofthe 1999 NS. We have had the huge advantage of hindsight, as well aswise counsel from many members of the social science researchcommunity, in revising the NS in these ways. Moreover, even where wehave diverged from the 1999 NS, we have learnt from it . We owe itsauthors a great deal. We also recognise that in due course the revisedNS will itself undergo revision. The world does not stay still.

Declaration of interest: Christopher Cordner chaired the joint working party revis ing theNational Statement on behalf of the National Health and Medical Research Council, theAustralian Research Council and the Australian Vice-Chancellors' Committee. ColinThomson was a member of that working party.

ENDNOTE

1 National Health and Medical Research Council, National Statement on Ethical Conductin Research on Humans, Canberra, 1999, available at : http://www.nhmrc.gov.au/publications/human/contents.htm This document is referred to in the text either a s'the 1999 NS' or simply as 'the NS'.

The recently revised version of the document is : National Health and MedicalResearch Council, Australian Research Council, Australian Vice-Chancellors 'Committee, National Statement on Ethical Conduct in Human Research, Canberra, 2007,available at: http://www.nhmrc.gov.au/publications/ synopses/ e 72syn.htm This versionis referred to in the text as 'the revised NS'. Institutions will be expected to reportagainst the revised NS from January 1, 2008.

Documents

No need to go! Workplace studies and the resources of the revisedNational Statement