Kate Reed

English

Research Papers in Economics

The Spectre of Research Ethics and Governance and the ESRC's 2010 FRE:
Nowhere Left to Hide?
by Kate Reed
University of Shefﬁeld
Sociological Research Online, 15 (4) 17
<http://www.socresonline.org.uk/15/4/17.html> 
10.5153/sro.2253
Received: 19 Oct 2010     Accepted: 23 Oct 2010    Published: 30 Nov 2010
Introduction
1.1 In 2007, I felt compelled to write about my experiences of applying for NHS ethics and governance
approval (NRES, formerly COREC) in a short article published in this journal (Reed 2007). That article was
a response to an earlier piece published in the THES which focused on the way that NHS research ethics
and governance procedures were stiﬂing research through tiresome bureaucratic procedures (Tysome
2007). Drawing on my experience of applying for ethical approval for a small qualitative project on antenatal
screening, I highlighted not only the bureaucratic nature of such procedures but also their inapplicability to
social science in general and qualitative research in particular (Reed 2007). As my somewhat farcical
experience showed, such an extensive and heavily bureaucratic process was not only time consuming but
also highly inappropriate. I did not feel that my research was any more ethically rigorous having gone
through this process.
1.2 In light of these experiences I decided on two strategies for future research: 1) work with clinicians
when undergoing research which requires NRES ethical review because clinicians are better placed to ‘play
the ethics game’ in the area of health research; 2) conduct social research that didn’t involve NHS staff or
patients. Until recently the latter strategy appeared more feasible given that ethics and governance
procedures for social scientists have tended to be far less onerous than those involving the health
services. However, with the implementation of the ESRC’s 2010 revised FRE, this may no longer be the
case. The extended form of ethical governance and review proposed under the revised FRE appears in
many ways to be just as bureaucratic and unsuitable to much social science research as NRES. It would
appear that there is no longer a place for social scientists to hide from the onslaught of extensive ethical
governance procedures.
FRE and the spectre of governance
2.1 Stanley and Wise (2010) pointed out that with the revised 2010 FRE social scientists wishing to apply
for ESRC funding will be faced with a signiﬁcantly extended system of governance for research ethics than
was previously experienced. This system of review will be mandatory. Research ethics committees (RECs)
will be responsible for reviewing all research proposals accepted by the ESRC. Furthermore, funding will
depend on REC review. The expanded review process will be ongoing, extending throughout the course of
a project’s life. This suggested framework resonates with ethics and governance under NRES. It applies a
‘one-size ﬁts all’ model to social science research and it signiﬁes a move away from discipline-speciﬁc
ethical review. Furthermore, the extensive audit procedures outlined under the revised FRE (which
speciﬁcally envisages ethical review as an ongoing process) risks stiﬂing research before it has even had
a chance to get going.
2.2 Upon a ﬁrst glance at the 2010 FRE, one is immediately ensnared by the bureaucratic tentacles of
extended ethics governance. For example, the revised ESRCs FRE ‘suggests’ that a range of information
must be considered by RECs when considering projects under ethical review. The requirements suggested
are similarly managerialist to those under NRES. For example, under ‘1.8 applications and protocols’ the
ESRC suggests that researchers submit a range of material, from research proposals to consent forms,
dissemination plans and information on advisory groups. As I argued in my earlier paper on COREC (Reed
2007), the volume of paperwork in itself is not the main problem here. The inclusion of extensive
information about method can actually be very useful in methodological reﬁnement (Reed 2007). The real
problem is the prescriptive nature of the paperwork. Underlying these ‘suggested’ requirements is a
Taylorist approach to research evaluation which reinforces the idea that research projects can all be
reviewed in the same way. Such an approach fails to acknowledge the speciﬁcity of research design and
application.
2.3 Furthermore, the much maligned ‘tick box’ approach to ethics and governance as commonly found in
the health sciences makes an appearance in the revised FRE. In order for RECs to decide a project’s fate
in terms of its eligibility for ‘light touch’ or ‘full ethics review’ the ESRC FRE 2010 recommends that a
checklist be compiled for each research project (see its Appendix A). It is deeply problematic to suggest
that risk to respondents in social science research can genuinely be assessed by box ticking (Reed 2007).
The ‘tick box’ approach to ethics assessment might be more appropriate to clinical research where therisks to participants may be more quantiﬁably measured (Kent et al. 2002). Have we in the social sciences
really learnt so little from this problematic approach used in the ethical governance of research in the NHS?
2.4 The one size ﬁts all approach reﬂected in the revised FRE also evidences a further lack of disciplinary
specialism during the review process. The RECs, responsible for reviewing all funded research proposals
should, according to the ESRC, be multidisciplinary and include one lay member with no afﬁliation to a
university or other research institution. They should reﬂect a broad range of research expertise and are not
discipline-speciﬁc. Can projects be appropriately reviewed by people who know little about the research
ﬁeld/discipline? I suggested in 2007 that this is one of the main problems with NRES; both the forms and
the ethics committees themselves are often not appropriately assembled in order to address the ethics and
validity of social science health research. Institutional RECs under the FRE could be just as inadequate in
examining the ethics of disciplinary speciﬁc social research. By failing to adequately address the ethics of
research, this process has the potential to undermine its own aim of affording protection to respondents.
2.5 A further problem under the revised FRE, as Stanley and Wise (2010) point out, is the radically
expanded nature of research governance auditing procedures. The ESRC FRE states that projects may be
subject to on-going review. Should other ethical issues arise during research, a project may be subject to
further review, possibly through evaluation by a project advisory group. Furthermore ad hoc audits of
research projects may take place on at least one ESRC project per year, randomly chosen. Again, this
approach is similar to NRES, where any new developments must be re-evaluated by ethics committees.
Such extensive micro-management through auditing places incredible constraints on research projects. Not
only will researchers be constrained at the start of the project but also during and after it, as plans for
dissemination now also comes under the purview of ethics. Furthermore, people may be put off developing
interesting angles to their research during ﬁeldwork due to the need to apply for further ethical review.
Faced with such endless bureaucracy and surveillance, many social researchers will simply give up on
data collection or produce research of questionable validity that tells us very little about what actually
exists out in the ﬁeld.
2.6 Overall, ethics and governance procedures through the ESRCs 2010 FRE mimic many of those found
under NRES. Such an extended form of ethics governance is prescriptive, insensitive to disciplinary
specialism and applies an audit-driven standardized approach to social research. Their principles of ethics
governance may severely restrict the scope and value of social science research before it has had a
chance to begin.
Fostering good practice or putting people off research?
3.1 The UK Research Integrity Ofﬁce (UKRIO 2009) states that research must be ‘governed’ by the
following principles; excellence, honesty, integrity, co-operation, accountability, training and skills, and
safety. However, as with other extensive ethical review and governance procedures, one is left to wonder
whether such procedures really do protect and safeguard respondents and whether that is even their
motive? As argued earlier, it is unclear as to how making ethics governance so extensive and so intrusive
makes research any more academically rigorous or ethically sensitive. The more paperwork requested, the
more research design and implementation becomes formulaic. Subsequently researchers respond to such
requests in a way that is similarly detached. Time and time again I have heard health researchers saying
‘oh I can do ethics in a day’. The idea that ‘doing ethics’ can be separated from ‘doing research’ really
highlights the ways in which extensive review processes are far removed from the process of evaluating
ethical issues in research.
3.2 In evaluating the 2010 FRE, one also wonders how much are its aims really about ensuring that
UKRIO’s ethics governance principles are put into action? The aims of these can in fact be set in a broader
context of a breakdown of professional trust and a ‘culture of fear’ under which health professionals and
researchers have operated since the Alder Hey scandal (Reed 2007). Undoubtedly, the extended ethics and
governance process outlined under the revised FRE can be situated in broader debates on the culture of
fear. Organizations and individuals are increasingly encouraged to take extra precautions in order to protect
themselves from perceived risks and dangers (Furedi 2002). However, with the ESRC’s revised FRE one
also has to wonder what other motives are at work. For example, is giving independent RECs more power
to assess ESRC research proposals a way of safeguarding respondents and ensuring sound research? Or
is it simply a way to devolve paperwork and responsibility away from the ESRC to other institutions? Such
a deferral of responsibility surely indicates another form of Foucauldian governance whereby we become
complicit in the construction of our own iron cage of research bureaucracy (Foucault, 1980, 1983)?
3.3 Furthermore, is this extended framework about ethical governance or is it about saving money for the
ESRC? With the spectre of severe funding cuts looming large with the 2010 Comprehensive Spending
Review, is this recommendation for extended forms of research governance just another way of putting
people off applying for what limited pots of money the ESRC has? Although all researchers applying to
ESRC must also apply for independent ethical review, they are most likely not to receive funding from the
ESRC. As the ESRC itself states, ‘a signiﬁcant proportion of applications are not funded’ (ESRC 2010: 10).
The rules of the ethics game have, therefore, changed. Researchers are no longer ‘playing ethics’ in order
to start research. They are playing in order to be considered for funding. Playing the ESRC ethics game
under the revised FRE is therefore a bit like playing poker, where the stakes might be high but your
chances of success are slim.
3.4 The extension of ethics procedures under FRE is perhaps the ﬁnal nail in the cofﬁn of applying for
ESRC funding for social scientists. Regarding my own research, I have focused my energies on health-
related research in the biomedical sciences. At least health ethics and governance under NRES are
currently separated from funding. Another of my strategies has been to work with clinicians who know
about ethical review under NRES. The ESRC FRE states duplication of ethical review should be avoided.
FRE guidelines state that applicants do not need to go through ethical review procedures under ESRC
remit if the study may fall under the rubric of other ethics committees. This means that for me there may
be beneﬁts in targeting NRES after all; at least theoretically, through NRES I can apply to target speciﬁc
patient groups rather than trying to ﬁnd alternatives under the FRE. Although the process is burdensome,
at least going through NRES widens the pool of groups of people that I can research.Re-instating the beneﬁts of social research
4.1 Despite trying to seek alternatives to the ESRC’s FRE, it is important here not to be defeatist. I agree
with Stanley and Wise (2010) that we also need to collectively resist ‘ethics creep’ in the social sciences.
If we accept the Foucauldian concept that governance is generated from the governed rather than imposed
by the government, then strategies for addressing ethics and governance creep should come from within
the social science community itself. While obviously we need some form of ethical governance, such an
extensive set of rules and regulations are simply not appropriate for much social research. Projects will be
required under the revised FRE to go through full ethical review when actually the potential to inﬂict
extensive harm or suffering on respondents/researchers really is minimal for much research in the social
sciences. A balance therefore needs to be struck in governance and ethical review between ﬂexibility and
regulation (Reed 2007, Wiles et al. 2007).
4.2 Instead of this constantly monitoring, sanitising and bureaucratising research, we need to go back to
the basics. We need to ask, what are the aims of social research and what are its many beneﬁts? Sadly,
amid the all-consuming obsession with ethics and respondent safety, we have forgotten that research can
have many beneﬁts to respondents. People often enjoy being interviewed, questioned about their
experiences and do not feel that research is an impingement on their liberty, dignity and well-being. Social
research can be and often is a very positive experience for many people - respondents and researchers
alike. Sadly, this aspect is totally absent in the discourse on research ethics. I am not suggesting that we
forget ethics. In fact, I am suggesting that we do the reverse, that we actually think in a more detailed and
nuanced way about what ethics is and how it applies to particular disciplines and in particular research
contexts. We need to focus on how to carry out ethically-sensitive research without crippling research
innovation and practice with bureaucratic, standardized, and inappropriate monitoring procedures. Above
all, we need to actively resist ethics creep or we may as well give up on the idea of researching the
experiences of others altogether.
References
ESRC (2010) Framework for Research Ethics (FRE)
<http://www.esrcsocietytoday.ac.uk/ESRCInfoCentre/Images/Framework%20for%20Research%20Ethics%202010_tcm6-
35811.pdf> (accessed October 2010)
FOUCAULT, M. (1980) Power/knowledge: Selected interviews & other writings. New York: Pantheon Books.
(Original work published 1972)
FOUCAULT, M. (1983) Afterword: The subject and power. In H. L. Dreyfus & P. Rabinow (Eds.), Michel
Foucault: Beyond structuralism and hermeneutics (pp. 208-226). Chicago: University of Chicago Press.
FUREDI, F. (2002) The Culture of Fear: Risk-taking and the morality of low expectation London:
Continuum.
KENT, J., WILLIAMSON, E., GOODNEOUGH, T., and ASHCROFT, R. (2002) ‘Social Science gets the
ethics treatment: research governance and ethical review’ Sociological Research Online, Vol 7, no. 4,
<http://www.socresonline.org.uk/7/4/williamson.html>
REED, K. (2007) ‘Bureaucracy and beyond: the impact of ethical review and research: Governance on
health research in the social sciences’ Sociological Research Online, 12(5),
<http://www.socresonline.org.uk/12/5/18.html>
STANLEY, L., and WISE, S. (2010) The ESRC’s 2010 Framework for Research Ethics: Fit for Research
Purpose? Sociological Research Online <http://www.socresonline.org.uk/15/4/12.html>.
TYSOME, T. (2007) ‘Health Research buckles under burden of red tape’ in The Times Higher Education
Supplement (25 May), pages 1 and 12.
UKRIO Code of Practice for Research:
<http://www.ukrio.org/resources/UKRIO%20Code%20of%20Practice%20for%20Research.pdf> (accessed
October 2010).
WILES, R., CROW, G,. CHARLES, V,. and HEATH, S. (2007) ‘Informed consent and the research process:
following rules or striking balances’ Sociological Research Online, Volume 12, Issue 2,
<http://www.socresonline.org.uk/12/2/wiles.html>.

Framework for Research Ethics (FRE) (accessed October

Health Research buckles under burden of red tape’

Informed consent and the research process: following rules or striking balances’

Social Science gets the ethics treatment: research governance and ethical review’

The Culture of Fear: Risk-taking and the morality of low expectation London:

UKRIO Code of Practice for Research: (accessed

The Spectre of Research Ethics and Governance and the ESRC's 2010 FRE: Nowhere Left to Hide?

http://www.socresonline.org.uk/15/4/17/17.pdf

The Spectre of Research Ethics and Governance and the ESRC's 2010 FRE: Nowhere Left to Hide?

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