Minorities
In addition to requiring the equitable selection of women
as research subjects, federal regulations require the equitable
selection of minorities
as research subjects [45 CFR
46.111.(a)(3)]. The inclusion of minorities
in research is important both to ensure that they receive an
equal share of the benefits of research and to ensure that they
do not bear a disproportionate burden (Please see Appendix 8 for a
detailed explanation).
Most diseases affect all population groups. In order to
contribute to the pool of generalizable knowledge, investigators
are required to include the widest possible range of population
groups in their research. However, sometimes minorities are
subject to a different risk. For example, some research pertains
to conditions such as sickle cell anemia or Tay Sachs disease
that specifically affect only a few minority
groups. Other research focuses on characteristics of diseases or
effectiveness of therapies in particular populations (e.g.,
HIV transmission, treatment for hypertension), and may also
concern conditions or disorders that disproportionately affect a
certain racial or ethnic group. Exclusion or inappropriate
representation of these groups, by design or inadvertence, would
be unjust. Further, to the extent that participation in research
offers direct benefits to the subjects (in HIV research, for
example, the receipt of a promising new drug),
under-representation of minorities denies them, in a systematic
fashion, the opportunity for direct benefit. A glaring example of
this type of research abuse of minority populations bearing
the burden of research can be found in the Tuskegee Syphilis
study, in which a group of African-American men suffering from
syphilis were left untreated, despite the availability of
penicillin, in order to study the natural course of the disease.
Due to these concerns, the federal regulations require that
research design include diverse populations. Investigators
submitting protocols for HSPC review which do not call for
heterogeneous study populations are required to justify, in
writing, in their submissions, why a homogeneous study population
has been chosen.
After a heterogeneous population has been chosen,
investigators should pay careful attention to the following two
issues:
- Special vulnerabilities: The DHHS recognizes that
certain subject populations may require additional
protections because they are economically or
educationally disadvantaged. The HSPC will attempt to
safeguard every subjects rights and welfare by
making sure that any possible coercion or undue influence
is eliminated (e.g., compensation that is not
commensurate with risk, discomfort, or inconvenience
involved, or recruiting in institutional settings where
voluntary participation might be compromised).
Investigators should address these issues specifically
when submitting protocol information to the HSPC for
review.
- Consent Form Presentation: Effort should always be
made to ensure that the consent process and the
relationship between the investigator and prospective
subjects are safeguarded. The federal regulations require
the translation of consent documents into the language
which is most easily understood by research subjects; the
possibility of illiteracy should be accounted for, as
should the need for communicating in non-English
languages. The FDA indicated in October 1995, that
non-English speaking subjects must have informed consent
form information presented in a written language that
they understand. [21 CFR 50.20
-27 and FDA Information Sheets, October 1,
1995, p 49] A potential subjects inability to read
or to read English is not an appropriate basis for
exclusion from most research.
The HSPC approved informed consent documents should be
available in English and other languages as appropriate to
the subject population(s). For investigators proposing to use
non-English language consent documents, quality assurance
procedures should be developed such as translation of the
consent document from English to the second language and then
back to English, to ensure that the information is correctly
conveyed. The HSPC is required to review all non-English
consent forms and recruitment tools. The role of cultural
norms of subjects should also be addressed. This information
should be provided in a clearly identifiable form to the HSPC
for review.
Contact OPRS
October 29, 2004
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