However, a substantial minority, particularly of 

 the investigators, felt that the procedure is an 

 unwarranted intrusion on the investigator's au- 

 tonomy, that the committee gets into inappro- 

 priate areas, that it makes judgments it is not 

 qualified to make, and that it has impeded re- 

 search. The most frequently indicated problem 

 (from a list of 10 problems) felt by board mem- 

 bers was getting members together for meet- 

 ings. Between a fourth and a third of the mem- 

 bers indicated problems due to the need for 

 rapid action in order to meet deadlines imposed 

 by funding agencies, the lack of precise DHEW 

 guidelines, and the time spent unnecessarily 

 reviewing research with little risk.'' 



Thousands of proposals are examined by re- 

 view boards, and the costs are borne by the insti- 

 tution. In some universities, the process provides 

 for no appeal of committee decisions. The imposi- 

 tion by the review boards of research protocol 

 objectionable to the investigators is also cited as 

 impeding research and limiting the freedom of 

 research. Some investigators allege they would 

 rather do no research than submit to such review 

 and regulation. 



Congress has recently considered bills that 

 would regulate research involving recombinant 

 DNA; this was in response to pressure for such 

 legislation initiated in the scientific community 

 itself. Concern about the conduct of such re- 

 search by industry or nongovernment-funded lab- 

 oratories has raised fundamental science and so- 

 ciety issues, such as the freedom of scientists to 

 investigate whatever interests them and the extent 

 of the Government's constitutional power to con- 

 trol scientific inquiry and the search for knowl- 

 edge beyond decisions to control funding. 



Present regulations controlling the use of hu- 

 man subjects, animals, and dangerous drugs or 

 chemicals, plus the application of OSHA safety 

 standards to research laboratories, may have sub- 

 stantial effects on the cost and complexity of con- 

 ducting research, and, in some cases, may impede 

 or prohibit the actual conduct of research even 

 beyond the impact of increasing costs. 



0MB Regulations 



Agencies such as the Department of Housing 

 and Urban Development (HUD) that support so- 

 cial science research find 0MB regulations on the 

 control, design, and use of survey questionnaires 



'Bated October 2. 1976, revised November 23, 1976. 

 288 BARRIERS TO OPTIMUM SUPPORT AND CONDUCT OF BASIC RESEARCH BY THE MISSION AGENCIES 



and protocol to be serious barriers to the conduct 

 of effective research. HUD comments: 



These regulations, when taken together with the 

 current government-wide drive to reduce paper- 

 work burdens on the public and private indus- 

 try, are so onerous as to be an effective barrier 

 to the performance of many social-science re- 

 search projects. Surveys of a properly drawn 

 sample population are, in fact, among the most 

 effective means of reducing paperwork bur- 

 dens, when contrasted with typical government 

 requests for information from an entire popula- 

 tion. 



Yet surveys are being treated by 0MB as 

 though they are just another paperwork burden. 

 Agency quotas have been imposed. No new 

 survey may be undertaken unless an older one 

 is discarded. Lengthy reviews are required of 

 every question in every survey instrument 

 aimed at ten or more respondents. The delay 

 from these reviews can be disastrously expen- 

 sive, if there is a contractor standing by waiting 

 to perform. 



In view of OMB's procedures for survey re- 

 view, HUD now uses a circuit-breaker clause in 

 its contracts to cut off any contractor expendi- 

 ture, when survey review time exceeds 60 days. 

 This merely transfers the direct costs of delay 

 from the government to the contractor. Ulti- 

 mately the costs will be reflected in contractors' 

 burden rates and partially or wholly come back 

 to the government. It could also lead to a drop- 

 out of contractors from this field. None of this 

 does the government, or the public it serves, 

 any good. 



These two kinds of regulatory problems with 

 OMB have a chilling effect on the conduct of 

 social science research by a mission agency. 



OMB regulations are considered by some agen- 

 cies to be a barrier to research dealing with hu- 

 man behavior in another way. HUD's response 

 includes the following comments: 

 We sense a very strong reluctance on the part 

 of OMB examiners to permit any research in- 

 volving a control population, which does not 

 receive a benefit given to the experimental 

 population. 



For example, HUD and a nonprofit agency 

 wished to test the hypothesis that job place- 

 ments would be higher for inner-city unem- 

 ployed persons receiving job counselling, if 

 they were also given housing counselling at the 

 same time. It was believed that job opportuni- 



