For nearly three decades, Canadian universities and colleges have operated under a mandate requiring Institutional Research Ethics Boards (REBs) to scrutinize research proposals and ensure adherence to the Tri-Council Policy Statement on Ethics and Research (TCPS2). This regulatory framework, established to safeguard research participants and uphold ethical standards, has become an increasingly contentious aspect of academic life. Despite its foundational intent, a growing chorus of researchers across disciplines is voicing systemic concerns and sharing challenging experiences, pointing to issues of "ethics sprawl" and the bureaucratization of risk management as significant impediments to scholarly inquiry.
The history of REB oversight in Canada can be traced back to the late 1980s and early 1990s, a period marked by heightened public awareness of research ethics issues, particularly following scandals in medical research. The Tri-Council Policy Statement, first released in its comprehensive form, aimed to standardize ethical review across federally funded research. Initially, the REB process was envisioned as a supportive mechanism, guiding researchers in navigating complex ethical considerations. However, over time, the nature and scope of this oversight have evolved, leading to the current landscape of perceived burden and inefficiency.
Escalating Scrutiny and Expanding Mandates
Paradoxically, despite persistent researcher concerns, the trend has been towards intensifying review processes rather than streamlining them. The 2022 update to the Tri-Council Policy Statement on Ethics and Research, for instance, saw its length increase by nearly 25 percent, reaching 288 pages. This expansion in documentation and guidance, while ostensibly aimed at greater clarity, has contributed to a perception of increased complexity. Furthermore, a critical gap exists in current research on REBs: there is a lack of independent evaluation to determine the extent to which these procedures genuinely protect participants. Crucially, there is no universally agreed-upon standard for measuring the effectiveness of REB oversight.
Anecdotal evidence from researchers suggests a deteriorating experience with the REB process. In numerous instances, short-term grants have expired before low-risk projects received ethics clearance. Feedback from REBs has often delved into areas that researchers consider to be outside the scope of ethical review, such as critiquing the content of literature reviews or demanding explanations for the risk of survey participation causing participant boredom. The multi-institutional ethics clearance process, a necessity for collaborative research, has been described as particularly arduous, marked by inconsistency and significant administrative overhead.
A National Survey Reveals Widespread Dissatisfaction
To move beyond individual experiences and gather a broader perspective, a national survey was conducted among social science researchers at Canadian universities. The survey, which consisted of 28 online questions, garnered responses from a convenience sample of 620 individuals across Canada. The researchers behind the survey had emailed 4,625 faculty members in Economics, Sociology, Political Science, and Anthropology, utilizing publicly available email addresses. No incentives were offered, and no follow-up attempts were made to encourage participation, aiming for a candid reflection of researchers’ genuine sentiments.
The survey results painted a stark picture of the impact of REB processes on Canadian research. A significant 58 percent of respondents indicated that the ethics review process deterred them from conducting research altogether. Large proportions of researchers reported avoiding interviews, surveys, and even routine classroom assessments due to the anticipated workload associated with REB applications. This scrutiny has also demonstrably shaped study designs, with over half of respondents admitting to omitting demographic variables such as sex, gender, and race. Furthermore, 70 percent reported avoiding research involving "vulnerable" populations to circumvent potential delays. This avoidance directly undermines research efforts aimed at understanding and addressing issues of equity and marginalization.
While some researchers acknowledged finding REB feedback useful for refining aspects like consent forms, anonymity protections, data security, or Indigenous data governance, the overwhelming majority of open-ended comments highlighted burdensome or distorting effects. REB decisions have, in some cases, necessitated major redesigns of research projects. Examples include excluding minors from studies, abandoning interviews with victims of violence, mandating active instead of passive consent for classroom studies, and blocking direct investigations of racist organizations. These interventions were frequently perceived as misaligned with the principles of critical inquiry, minimal-risk qualitative work, and community-engaged research. For multi-institutional projects, researchers encountered duplicative and inconsistent reviews, even when prior ethical approval had been secured elsewhere. Moreover, awareness and application of TCPS exemptions for quality assurance, program evaluation, and anonymous data were reported as notably low.
Impact on Teaching and Future Researchers
A particularly concerning finding of the survey related to the impact of REB procedures on teaching and the training of future researchers. A substantial 71 percent of faculty respondents stated they avoided designing assignments that involved data collection due to concerns about REB workload or delays. The majority of these faculty members had advised their graduate students to steer clear of data collection activities. Furthermore, almost half of the relevant faculty reported that students were unable to conduct research during community placements because of REB limitations. This suggests a systemic impediment to pedagogical approaches that rely on hands-on research experience and the practical application of research methodologies.
The overarching perception among respondents was that expanding definitions of "risk," coupled with questionable approaches to risk mitigation, created discouraging levels of hassle and gatekeeping behaviors. These bureaucratic complexities add significant strain to the research endeavor. This is particularly noteworthy given the lack of clear evidence demonstrating that specific REB requirements demonstrably enhance participant protection in many of these low-risk scenarios.
The survey authors acknowledged the potential for sample bias, with respondents potentially more inclined to share negative experiences. However, they posed a critical question: "Even so, we wonder why are so many people having such negative experiences?" This question points to a systemic issue that transcends individual researcher aptitude or isolated instances of poor luck.
Resistance to Scrutiny and Calls for Reform
The challenges encountered by researchers in conducting this very study underscore the divisive nature of the REB issue. During the data collection phase, an REB official from one university contacted the researchers, demanding they cease contacting faculty members, asserting that REB clearance was required from their institution to email their staff via publicly posted addresses. At conference presentations where REB officials were present, the researchers reported being told they were not sufficiently emphasizing the positive aspects of REB review. Anonymous manuscript reviewers have also suggested reframing arguments to highlight researchers’ deficiencies in understanding TCPS protocols, rather than focusing on the systemic flaws within the REB process itself. Invitations extended to TCPS representatives to participate in scholarly panels discussing the impact of REB practices have reportedly gone unanswered.
While all responsible researchers agree on the fundamental importance of research ethics in study design, a significant divergence exists regarding the effectiveness and perceived "aggressive nature" of policing researchers, particularly concerning studies deemed to be of extremely low risk. REB practices are not only seen as dissuading vital research but also as actively inhibiting crucial aspects of teaching, especially in areas of research methods and the practical application of theory to lived experience.
Concrete Recommendations for Improvement
In response to the extensive feedback from over 600 Canadian researchers, the authors of the survey have put forth four concrete recommendations, which they believe are readily adoptable:
- Streamline Review for Minimal-Risk Research: Implement tiered review processes that significantly expedite the review of studies deemed to be of minimal risk. This could involve pre-approved protocols for common minimal-risk methodologies or expedited review committees for such applications.
- Clarify and Enforce TCPS Exemptions: Enhance awareness and consistent application of existing TCPS exemptions for quality assurance, program evaluation, and the use of anonymous or de-identified data. Training for REB members on these exemptions is crucial.
- Standardize Multi-Institutional Review: Develop a more cohesive and standardized approach to multi-institutional ethics review. This could involve establishing lead REBs for multi-jurisdictional projects or creating mechanisms for mutual recognition of prior approvals with clear guidelines.
- Focus on Participant Protection, Not Process Policing: Reorient REB focus towards demonstrably enhancing participant protection rather than enforcing overly bureaucratic and often subjective interpretations of risk. This requires a shift towards evidence-based evaluation of the effectiveness of specific REB requirements.
The Path Forward
The question now remains: "Who will listen to them?" The Tri-Council is currently soliciting feedback on proposed updates to the Tri-Agency Framework: Responsible Conduct of Research, with a deadline of April 17, 2026. This presents a critical opportunity for researchers, institutions, and the wider academic community to voice their concerns and contribute to meaningful reform. The findings of this national survey and the proposed recommendations offer a data-driven foundation for dialogue and action, aiming to rebalance the scales and ensure that ethical oversight serves its intended purpose of fostering robust and ethical research without becoming an undue impediment to scholarly discovery and pedagogical innovation. The ongoing dialogue surrounding REB practices highlights a fundamental tension between necessary oversight and the practical realities of conducting research in a rapidly evolving academic landscape. Addressing these concerns is vital for the continued health and productivity of Canadian research.
