Manuel B. Garcia

Manuel B. Garcia serves as the Senior Director for Educational Technology and Digital Learning at FEU Institute of Technology, Manila, Philippines. Read More

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Can You Disagree With an Ethics Committee’s Requested Change?

Disagreement with an ethics committee is not the same as ignoring its decision. Researchers can explain concerns, provide evidence, seek clarification, and propose alternatives through the review process while respecting the committee's authority over approval.

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01 · The Question

Are you allowed to tell the ethics committee that you think its requested change is wrong?

An ethics committee asks you to revise your study. You read the comment carefully and still believe the requested change is unnecessary, based on a misunderstanding, disproportionate to the risk, inconsistent with the methodology, or addressable in another way.

Do you simply have to agree?

Researchers are not expected to abandon reasoned scientific judgment when an ethics application is reviewed. Ethics review is a process in which committees may request modifications or clarification and researchers respond. The important distinction is between disagreeing through that process and ignoring a committee's requirements after deciding privately that you know better.

02 · The Short Answer

You can raise a reasoned disagreement through the review process

In Brief

Yes. You can explain why you disagree with an ethics committee's requested change, provide relevant evidence, clarify misunderstandings, and propose an alternative that addresses the committee's underlying ethical concern.

That does not mean you can disregard the committee's determination or conduct the study according to your preferred version without the required approval. The available route for reconsideration, further review, or appeal depends on the committee's written procedures and the status of the application.

03 · What You Need to Know

Disagreement and noncompliance are different things

A researcher can disagree with a reviewer and still participate properly in ethics review.

OHRP's current guidance for U.S. IRBs recommends written procedures covering how required modifications or clarifications are communicated, how investigators' responses are subsequently reviewed, and how reasons for disapproval and opportunities for investigators to respond are handled. For covered research, the review process therefore explicitly anticipates communication between investigators and the IRB rather than treating every committee comment as the end of discussion.

Other ethics systems may organize this exchange differently. The general distinction remains important.

Reasoned disagreement You explain your concern through the authorized review process and ask the committee to consider clarification, evidence, or an alternative.
Noncompliance You conduct research in a way that is not authorized because you personally decided the committee's requirement should not apply.

The first can be part of responsible scholarly exchange. The second can create a serious research-governance problem.

Before disagreeing, make sure you understood the comment correctly

Some apparent disagreements disappear once the comment is unpacked.

"Please address how participant distress will be managed" may be a request for additional explanation rather than a demand to remove the sensitive questions. "Please revise the recruitment process to address possible coercion" may allow several solutions rather than prescribing one.

Read the decision letter carefully. Separate:

  • questions seeking clarification;
  • requests for additional information;
  • suggested wording;
  • specific modifications required for approval;
  • conditions attached to approval;
  • reasons the committee cannot yet approve the study.

If the wording remains unclear, use the committee's permitted communication route to ask what concern the requested change is intended to resolve.

Ask what ethical criterion is at issue

A productive disagreement begins with the committee's concern rather than your preferred solution.

Is the issue risk minimization? Voluntariness? Privacy? Confidentiality? Fair participant selection? Adequacy of consent? Scientific justification? Additional protection for a particular population?

Once the concern is clear, you can determine whether you actually disagree with the ethical objective or only with the particular method proposed to achieve it.

Often it is the latter.

You can agree with the concern and disagree with the solution

This is one of the most useful distinctions in ethics correspondence.

You might agree that direct recruitment by a supervisor could create perceived pressure but disagree that the entire employee population must therefore be excluded. You might agree that identifiable longitudinal data create confidentiality risk but disagree that complete anonymity is feasible because the design requires repeated observations to be linked.

In those situations, state both parts clearly:

Concern "We agree that the proposed recruitment relationship could create perceived pressure to participate."
Problem with the requested change "Excluding this population would prevent the study from addressing the research question for which it was designed."
Alternative "We therefore propose independent recruitment and a procedure preventing supervisors from knowing who accepts or declines the invitation."
Request "We respectfully ask whether this alternative would adequately address the committee's concern."

The exact wording will vary, but the reasoning is stronger than simply writing "We disagree."

Use evidence when the disagreement depends on facts

If you believe the requested change rests on an incorrect factual assumption, provide evidence relevant to that assumption.

This might include official guidance, methodological literature, validation documentation for an instrument, evidence about the frequency or severity of a procedure's risks, technical information about data security, or a concise explanation of the study design.

Do not overwhelm the committee with citations simply to make the response look authoritative. Evidence should resolve the disputed point.

Explain methodological objections as methodological consequences

If your objection is that the requested change would weaken the research, specify how.

Would it invalidate an instrument? Prevent measurement of the primary outcome? Introduce systematic selection bias? Destroy a longitudinal linkage? Make groups incomparable? Change the intervention being tested?

The deeper problem of responding when a requested ethics change may harm the methodology deserves this level of precision because "we prefer our original method" is rarely enough.

Do not treat disagreement as a negotiation over participant protection

Researchers sometimes approach ethics comments as though the objective is to persuade reviewers to remove inconvenient requirements.

A better question is whether the committee's ethical concern can be addressed adequately in another way.

If the requested change is necessary to satisfy an applicable ethical or regulatory requirement and no acceptable alternative exists, methodological preference does not automatically override that requirement. The study may need to change, be reconsidered more fundamentally, or not proceed in its proposed form.

The committee should have reasons for significant adverse decisions

Within the U.S. HHS and FDA regulatory context, if an IRB disapproves research, written notification must include the reasons for the decision and provide the investigator an opportunity to respond in person or in writing. OHRP guidance also states that IRB meeting minutes must document the basis for requiring changes or disapproving research.

This is useful as an example of a review system that recognizes the importance of reasons and investigator response. Do not assume that the same procedural entitlement exists in identical form in every jurisdiction. Check the rules governing your committee.

A response to comments is not necessarily an appeal

If a committee asks you to revise the protocol and you explain why you prefer an alternative, you are usually still participating in the ordinary review process.

An appeal generally refers to a more formal challenge to a decision under procedures established by the institution or ethics system. Whether such a procedure exists, which decisions can be appealed, who considers the appeal, and what outcomes are possible vary considerably.

Do not escalate an ordinary clarification into a formal dispute unnecessarily. Conversely, if ordinary dialogue has concluded and the committee has issued a final decision, determine whether a formal appeal process is available.

Approval with conditions does not mean every issue remains negotiable after you start

Under OHRP guidance, an IRB can approve covered research with conditions in certain circumstances when it can make the required approval determinations assuming specified conditions are satisfied. It can also require modifications and defer the study for further review when the outstanding issues prevent approval.

The distinction matters because the researcher's freedom to proceed depends on the actual decision. Do not assume that "conditional" means "start now and discuss the remaining disagreement later."

Before beginning research, determine what the committee's conditional decision actually permits.

You cannot solve disagreement by making an unapproved change yourself

Suppose the committee approves your proposed alternative, but after recruitment begins you decide the original procedure would work better after all.

That is no longer the same disagreement. It is a proposed change to approved research.

For research subject to the U.S. Common Rule, proposed changes generally require prior IRB review and approval before implementation except where necessary to eliminate apparent immediate hazards. OHRP's compliance materials document failures to obtain prior review of protocol changes as regulatory problems.

Watch Out

The fact that you previously argued for a procedure does not authorize you to use it. What matters operationally is the version of the research currently approved under the applicable review process.

Professional tone matters because the objective is resolution

A response can be firm without becoming adversarial.

Avoid statements such as "The committee clearly misunderstands qualitative research" or "This requirement makes no scientific sense." Even when frustration is understandable, those formulations do not explain the methodological issue or help reviewers resolve it.

State what you understand the concern to be, what evidence or reasoning leads you to a different conclusion, and what action you propose.

The ethics committee does not need ceremonial agreement. It needs a response it can evaluate.

04 · A Practical Example

Disagree with the proposed safeguard without dismissing the concern

Hypothetical Example

Interviewing nurses about workplace safety

A researcher proposes confidential interviews with nurses about workplace safety incidents. The ethics committee is concerned that participants could identify colleagues or managers and requests that all questions about specific incidents be removed.

The researcher believes that removing discussion of actual incidents would make it impossible to answer the research question, which concerns how safety problems are recognized and handled in practice.

Unhelpful response "We disagree. Specific incidents are essential to qualitative research, so we will retain the questions."
Identify the concern The committee appears concerned about identifiable third-party information and possible occupational consequences if interview material is disclosed.
Explain the disagreement The researcher explains that concrete accounts of safety incidents are necessary to examine the processes central to the research question and that removing them would change the phenomenon being studied.
Propose safeguards The researcher proposes instructing participants not to use names where possible, removing or generalizing identifying details during transcription and reporting, restricting raw-data access, and avoiding quotations whose contextual details create an unacceptable identification risk.
Request reconsideration The researcher asks whether these protections would address the committee's concern while allowing the incident-focused questions to remain.

The researcher has disagreed with the requested change, but not with the need to protect confidentiality. That distinction gives the committee something substantive to reconsider.

05 · What Researchers Often Get Wrong

Common mistakes when disagreeing with ethics reviewers

Misconception

You must agree with every requested change

You can provide clarification, evidence, methodological reasoning, or an alternative through the review process. Whether the committee accepts your response is a separate question.

Misconception

If you disagree, the committee will automatically reject the study

Reasoned responses to requested modifications or clarifications are a normal feature of many review processes. Focus on the substance of the concern and respond professionally rather than treating disagreement itself as confrontation.

Misconception

Disagreeing means refusing to comply

No. You can ask the committee to reconsider a requirement while continuing to respect its authority over approval. Noncompliance occurs when research is conducted outside the authorization that applies to it.

Misconception

Scientific expertise automatically settles the disagreement

Researchers may have greater expertise in a particular method or subject area, but the committee may be addressing an ethical consequence of that method. Explain the technical issue while engaging directly with the participant-protection concern.

Misconception

If the committee rejects my alternative, I can choose whichever option I think is best

No. If the alternative is not approved, it is not authorized merely because you believe it is superior. Use any available reconsideration or appeal process rather than conducting the study according to an unapproved version.

06 · What This Means for You

Disagree in a form the committee can actually evaluate

A useful response is specific enough that reviewers can identify exactly what you contest and exactly what you propose instead.

A simple decision framework

If you are unsure what the committee means
Seek clarification before drafting a methodological or ethical rebuttal to a requirement that may not exist.
If you agree with the ethical concern but not the requested solution
Say so explicitly and propose another safeguard addressing the same concern.
If you believe the request rests on a factual or methodological misunderstanding
Explain the issue concisely and provide relevant evidence rather than relying on assertion.
If the requested change is acceptable
Make the revision consistently and identify where it was made rather than manufacturing a disagreement unnecessarily.
If ordinary review does not resolve the disagreement
Check whether the institution provides reconsideration, consultation, escalation, or a formal appeal process.
If the committee has not authorized your preferred procedure
Do not implement it while the disagreement remains unresolved.

When several comments are involved, respond to them separately rather than writing one general defense of the study. A structured response makes it easier to show how each committee comment or condition has been addressed.

07 · A Quick Checklist

Check your disagreement before sending it

Before asking the committee to reconsider a requested change, check:
You have identified exactly what the committee requested rather than responding to an assumption about its meaning.
You understand the ethical concern or approval criterion underlying the request.
Your disagreement explains a concrete scientific, ethical, factual, or operational issue rather than simply stating a preference.
Relevant evidence supports factual or methodological claims when evidence is available.
You have considered whether an alternative safeguard can address the committee's concern.
Your response distinguishes changes you accept from changes you are asking the committee to reconsider.
Your tone is professional and focused on resolving the ethical issue rather than proving that a reviewer is wrong.
You understand what research activities, if any, are currently authorized while the disagreement is unresolved.
08 · Frequently Asked Questions

Questions about disagreeing with an ethics committee

Am I allowed to say that I disagree with an ethics committee comment?

Yes. You can explain why you disagree and provide clarification, evidence, or an alternative through the committee's review process. The committee still determines whether the study satisfies its approval requirements.

Should I change the protocol first and argue about it later?

If you believe the requested change creates a significant problem, raise that concern before treating the revision as settled. Once an acceptable approach is determined, ensure the final protocol and supporting documents reflect what the committee actually approved.

Can I ask the committee why it requested a change?

Use the communication procedures available at your institution. Understanding whether the concern involves risk, consent, privacy, participant selection, methodology, or another issue can make your response much more precise.

Can I propose a different solution?

Yes, you can propose an alternative and explain how it addresses the same ethical concern. The alternative should not be implemented unless and until it is accepted through the applicable review process.

Does disagreeing with a requested change count as an appeal?

Usually not automatically. Responding to requested modifications or clarifications can be part of ordinary ethics review. A formal appeal is a separate institutional procedure where one exists and is generally relevant after a decision or disagreement reaches the stage defined by that procedure.

Can the ethics committee simply reject my alternative?

The committee may determine that your proposed alternative does not satisfy the ethical or regulatory criteria it must apply. If you continue to disagree, check what further response, reconsideration, or appeal procedures are available rather than implementing the alternative independently.

Can I continue the study while the disagreement is being resolved?

Only to the extent clearly authorized by the existing approval or committee decision. Do not assume that unaffected activities may continue or that conditional language permits enrollment. Verify the study's current approval status and any restrictions imposed by the committee.

09 · The Bottom Line

You can disagree without disregarding the review process

The Bottom Line

You can disagree with an ethics committee's requested change by explaining your reasoning, supplying relevant evidence, clarifying misunderstandings, and proposing an alternative that addresses the underlying ethical concern.

What you cannot do is convert disagreement into private permission to conduct an unapproved version of the study. Keep the discussion within the authorized review process, distinguish ordinary response from formal appeal, and make sure the research ultimately conducted is the research the committee has authorized.

10 · Sources and Further Reading

Authoritative guidance on ethics committee decisions and investigator responses

11 · Cite this Guide

How to Cite This Guide

This guide is intended to be read, shared, and used in research, teaching, and academic work. If you draw on its ideas, explanations, or other content, please acknowledge the source by citing the guide. Doing so gives appropriate credit and helps your readers locate the original resource.

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