| Department: |
UAMS Human Research
Advisory Committee |
|
Policy Number: |
17.10 |
|
Section: |
Special Populations |
|
Effective Date: |
July 31, 2002 |
|
Revision Date: |
October 10, 2002 |
SUBJECT: Students, Employees and
Healthy
Volunteers
Healthy
Volunteers.
Special concerns surround the involvement of healthy persons who volunteer to
participate in research. Primarily, the principles involved are beneficence and
respect for persons. In the Belmont Report, the National Commission for
the Protection of Human Subjects of Biomedical and Behavioral Research stated
the two general rules that describe beneficent actions as: (1) do not harm; and
(2) maximize possible benefits and minimize possible harms. Volunteers for whom
no therapeutic benefit can result from participation in research should,
therefore, be exposed to risks that are minimized to the greatest extent
possible. While the minimization of risks is an important requisite for any
research involving human participants, the altruistic motivation of the healthy
volunteer's agreement to participate (i.e., of contributing to scientific
knowledge for the benefit of society) heightens the concern for the risks to
which such participants should ethically be exposed.
The principle of respect for persons requires that research
participants be, where capable of doing so, allowed to act autonomously and to
express their right of self-determination. These principles are effectuated
through the process of informed consent, which involves providing subjects with
all relevant information about the study, including the risks and benefits
involved, in clear and simple language, and ensuring that the information is
understood and appreciated. In research involving healthy volunteers,
particularly where the research involves more than minimal risk, the HRAC must
ensure that any monetary payments to subjects are not so great as to constitute
an undue inducement. The HRAC should seriously scrutinize the payment schedules
to ensure that any compensation offered is commensurate with the time,
discomfort, and risk involved. Where a research procedure involves serious
discomfort and/or the real, though slight, possibility of serious harm, the HRAC
should pay particular attention to the proposed study population and whether it
may comprise persons who are likely to be vulnerable to coercion or undue
influence, such as persons who are educationally or economically disadvantaged.
The federal regulations require that the HRAC employ special safeguards under
such circumstances [38CFR16.111(b); 45 CFR 46.111(b)].
One area where healthy volunteers are employed in research is in
Phase 1 drug trials. The justification for the involvement of healthy, healthy
subjects is the need for volunteers whose experience with the trial materials is
more easily analyzed because of the existence of fewer confounding factors.
While Phase 1 trials are the first use of experimental drugs and devices in
humans, preliminary studies involving animals provide investigators with data
indicating a high likelihood of safe use in humans. Studies have indicated that
the risk of injury from participating in Phase 1 studies is small, about the
same as the risk of being injured while working as an office secretary [Levine
(1982)]. The likelihood of risk, including the availability of animal data,
should be scrutinized by the HRAC.
Healthy volunteers, like students and employees, should be recruited
through general announcements or advertisements, rather than through individual
solicitations. Personal solicitations increase the likelihood that participation
will be the result of undue influence, either because of the relationship
between the recruiter and the prospective subject, or methods of communication
employed by the recruiter that may act to persuade prospective subjects to
participate, thus compromising the voluntariness of the agreement to
participate.
Investigators and the HRAC should carefully consider what will happen
if and when a healthy volunteer should become sick or be injured during the
research. As with any research involving human subjects, such issues should be
clearly spelled out in the informed consent document, and should be reviewed
carefully with the prospective subject. For example, subjects should be told:
whether any medical treatments will be made available should injury occur and,
if so, what they consist of; whom to contact should a research-related injury
occur; and that they may discontinue participation at any time without penalty
or loss of benefits to which they would otherwise be entitled
[38CFR16.116(a)(6-8); 45 CFR 46.116(a)(6-8)]. In addition, where appropriate
subjects should be told whether they will be dropped from the study in the event
of injury or illness, and whether they will be required to pay for treatment of
research-related injuries or illness [38CFR16.116(b)(2-3); 45CFR46(b)(2-3)].
Where illness in healthy volunteers does occur, particularly during a drug
study, investigation by an independent physician may be warranted. [See
Fazackerley, Randall, and Pleuvry (1987).]
The issues raised by the involvement of healthy subjects in genetic
research are discussed in Guidebook Chapter 5, Section H, "Human Genetic
Research."
Students. Two questions that have been posed are whether students -- medical students, in particular -- should be allowed to participate in biomedical research (and whether special protections should be adopted to restrict their participation), and whether participation in research can appropriately be included as a course component for course credit. The problem with student participation in research conducted at the university is the possibility that their agreement to participate will not be freely given. Students may volunteer to participate out of a belief that doing so will place them in good favor with faculty (e.g., that participating will result in receiving better grades, recommendations, employment, or the like), or that failure to participate will negatively affect their relationship with the investigator or faculty generally (i.e., by seeming "uncooperative," not part of the scientific community).
Consent must state that students are allowed to refuse participation
or withdraw early from a study without affecting their academic standing at
UAMS. Prohibiting all student
participation in research, however, may be an overprotective reaction. An
alternative way to protect against coercion is to require that
faculty-investigators advertise for subjects generally (e.g., through
notices posted in the school or department) rather than recruit individual
students directly. As with any research involving a potentially vulnerable
subject population, the HRAC should pay special attention to the potential for
coercion or undue influence and consider ways in which the possibility of
exploitation can be reduced or eliminated.
Confidentiality is a concern raised by the involvement of students as
subjects in research. The HRAC should be aware that research involving the
collection of data on sensitive subjects such as mental health, sexual activity,
or the use of illicit drugs or alcohol presents risks to subjects of which they
should be made aware and from which they should be protected, to the greatest
extent possible. The close environment of the university amplifies this problem.
Employees.
The issues with respect to employees as research subjects are essentially
identical to those involving students as research subjects: coercion or undue
influence, and confidentiality.
Employee research programs raise the possibility that the decision will
affect performance evaluations or job advancement. It may also be difficult to
maintain the confidentiality of personal medical information or research data
when the subjects are also employees, particularly when the employer is also a
medical institution [Meyers (1979)]. For issues regarding compensation see HRAC
policy 14.2.