Beyond protection?

For nearly the past three decades, Canadian universities and colleges have been required to have an Institutional Research Ethics Board (REB) vet studies and ensure compliance with the Tri-Council Policy Statement on Ethics and Research (TCPS2). From the beginning, researchers have expressed systemic concerns and shared difficult experiences with the functioning of this regulatory regime. Key issues are ethics sprawl or creep, and the bureaucratization of risk management.  

Yet despite these concerns, arguably the trend has been to intensify review, not streamline it. When the Tri-Council Policy Statement on ethics and research was updated in 2022, its length was increased by nearly 25 percent to 288 pages. And in the raft of research on REBs, there is no evaluation of the extent to which the procedures actually protect participants – indeed, there is no agreed-upon standard of effectiveness. 

In the personal experiences of the authors, the REB process has become increasingly worse. On more than one occasion, short-term grants have expired before ethics clearance was received on low-risk projects. Feedback from REBsdelved into areas that the researchers believed to be out-of-scope (e.g. content of literature reviews, or being asked to address the risk that survey participation would ‘bore’ participants). Multi-institutional ethics clearance processes are extremely onerous and consistently inconsistent.  

However, we did consider the possibility that perhaps we were just bad at ethics applications or had unusually bad luck with the process.  

So to acquire a broader sense of our colleagues’ REB experiences, we decided to conduct a national survey of social science researchers at Canadian universities. We ended up with a convenience sample of 620 individuals across Canada who answered our 28-question online survey. We emailed 4625 faculty members in Economics, Sociology, Political Science and Anthropology from publicly available email addresses and invited them to complete our web survey. We offered no incentives and no follow-ups were made.  

Many respondents described REB processes as onerous, with 58 per cent saying ethics review deterred them from doing research at all. Large proportions avoided interviews, surveys, or even routine classroom assessment because of anticipated workload. REB scrutiny also shaped study design: over half of respondents reported omitting demographic variables (e.g., sex, gender, race) and 70 per cent avoided work with “vulnerable” populations to sidestep delays, undermining research on equity and marginalization. 

Some researchers found REB feedback useful for refining consent forms, anonymity protections, data security, or Indigenous data governance. However, most openended comments highlighted burdensome or distorting effects. REB decisions sometimes forced major redesigns (e.g., excluding minors, abandoning interviews with victims of violence, requiring active instead of passive consent for classroom studies, blocking direct study of racist organizations), and were viewed as particularly misaligned with critical inquiry, minimalrisk qualitative work and community-engaged research. Multiinstitutional projects faced duplicative and inconsistent reviews, despite prior approval elsewhere. Awareness and application of TCPS exemptions for quality assurance, program evaluation and anonymous data were low. 

We were particularly concerned about reports of the impact of REB procedures on teaching.  71 per cent of faculty respondents said they avoided designing assignments with data collection because of concerns about REB workload or delay, the majority had advised graduate students to avoid data collection and almost half of relevant faculty said students couldn’t do research during community placements because of REB limits. 

Overall, respondents perceived expanding definitions of “risk” and questionable approaches to mitigation, discouraging levels of hassle and gatekeeping behaviours that add complexity to the research endeavour – which is notable since the REB system has done little to show that specific requirements enhance protection to research participants. 

We recognize that our sample might be biased towards responding in negative ways, but even so, we wonder why are so many people having such negative experiences? 

Even in the course of conducting, discussing and publishing this research, we have encountered curious push-back. Bizarrely, during data collection, an REB official from one university emailed us and told us we had to stop contacting their faculty members because we had not obtained REB clearance from their university to contact their staff at posted emails. In conference presentations where REB officials have been present, we have been told that we were not emphasizing the positive aspects of REB review sufficiently, and in anonymous reviews for our manuscripts on graduate student and faculty experiences, we have been asked to reframe our arguments to highlight deficiencies of researchers in reading and understanding the TCPS protocols. Invitations to TCPS representatives to participate on scholarly panels about the impact of REB practices have not been answered. 

This is definitely a divisive issue. While all responsible researchers would agree that research ethics are an important part of study design, many simply disagree with the effectiveness or aggressive nature of policing researchers, especially with regards to extremely low-risk studies. Not only do REB practices serve to dissuade research, they also act to inhibit important aspects of teaching, particularly research methods and how ‘theory’ works with lived experience.  

In the course of this study, we reviewed the literature and listened to our respondents to create four concrete recommendations that we believe to be fairly easy to adopt: 

• Broaden TCPS exemptions (similar to the U.S. “common rule”) so minimalrisk survey, interview and observational research with adults can be registered with the REB, but without any review beyond a determination that the research is minimal risk.  This would let boards focus on higherrisk projects. 

• Require all REBs to post a clear, simple, preferably standardized exemption process and form, and actively promote understanding of existing exemptions (e.g., via logic models and sample forms) to reduce unnecessary reviews and to support experiential and partnerbased research. 

• Use TriCouncil spending power to mandate reciprocal acceptance of REB reviews across TCPS2 institutions: one full review per multisite study, with other sites only filing that approval locally rather than rereviewing. 

• Reinforce the REBs role to protect participants, and minimize their role as institutional gatekeepers of access to students, staff, or communities. 

These are our recommendations, based on the experience and feedback of more than 600 Canadian researchers. Now who will listen to them?  

The Tri-Council is currently seeking feedback on the proposed updates to the Tri-Agency Framework: Responsible Conduct of Research until April 17, 2026. We encourage readers to respond.