December 4, 2013 SACHRP Letter to the HHS SecretaryDecember 4, 2013
The Honorable Kathleen Sebelius
Secretary of Health and Human Services
200 Independence Avenue, S.W.
Washington, D.C. 20201
Dear Ms. Sebelius:
On behalf of the Secretary’s Advisory Committee on Human Research Protections (SACHRP), I respectfully submit for your consideration comments relevant to the Department of Health and Human Services (HHS) human subjects protection regulations at 45 CFR part 46. These comments, originating in the Subcommittee for Harmonization, were passed by SACHRP at their July 2013 meeting.
Recommendations from the Subcommittee on Harmonization
On October 28, 2009, SACHRP approved a recommendation establishing a Subcommittee on Harmonization (SOH). SACHRP’s charge to this subcommittee was to identify and prioritize areas in which regulations and/or guidelines for human subjects research adopted by various agencies or offices within HHS would benefit from harmonization, consistency, clarity, simplification and/or coordination. The Subcommittee will develop recommendations for consideration and possible adoption by SACHRP, to harmonize and simplify these guidelines and regulations. The goal of this subcommittee effort is to reduce unnecessary burdens on research efforts, thus resulting in better allocation of research resources and promoting the safety and welfare of human subjects.
On July 11 SACHRP passed the attached comment regarding the June 4, 2013 FDA Request for Comment relating to the availability of masked and de-identified non-summary safety and efficacy data.
On behalf of SACHRP, I would like to thank you for your consideration of this report. The committee, the Subpart A Subcommittee and the Subcommittee on Harmonization have been actively working in pursuit of their charges, and we look forward to continuing this work to enhance human subjects protections for the benefit of all Americans.
Jeffry R. Botkin, M.D.
Chair, Secretary’s Advisory Committee
on Human Research Protections
cc: Jerry Menikoff, M.D., J.D., Executive Secretary, SACHRP
Julia Gorey, J.D., Executive Director, SACHRP
Jeffrey R. Botkin, M.D., M.P.H.
University of Utah
Salt Lake City, Utah
Albert J. Allen, M.D., PhD.
Eli Lilly & Co.
Carl H. Coleman, J.D.
Seton Hall Law School
Newark, New Jersey
Gary Chadwick, Pharm. D., MPH, C.I.P.
University of Rochester
Rochester, New York
Thomas Eissenberg, Ph.D.
Virginia Commonwealth University
Owen Garrick, M.D., M.B.A.
Bridge Clinical Research
Steven Joffe, M.D., MPH
Dana-Farber Cancer Institute
Susan Krivacic, M.P. Aff.
PBG Consulting LLC
Pilar Ossorio, J.D.
University of Wisconsin Law School
Suzanne M. Rivera, Ph.D., M.S.W.
Case Western Reserve University
Lainie F. Ross, M.D., PhD.
University of Chicago
Jerry Menikoff, M.D., J.D.
Julia Gorey, J.D.
Content last reviewed on December 4, 2013