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An
Interesting Career in Psychology:
Federal
Regulatory Officer for Protection of Human Subjects
Tom
Puglisi, PhD, Federal Office for Protection from Research
Risks
It was Spring of 1979, and I was a first-year faculty member. The Dean asked
our department chair to nominate someone to head the "Human Subjects
Committee." Eager to advance my fledgling career, and believing that
chairing a university committee might help when tenure time rolled around, I
volunteered. Now, 20 years later, I'm still in the business of protecting
human subjects--currently as Director of Human Subject Protections in the
Federal Office for Protection from Research Risks (OPRR).
Trained as a lifespan developmental psychologist, I never dreamed that I
would end up a federal bureaucrat. However, I should have realized I would be
influenced by the same developmental challenges, choice points, and just plain
random events that influence everyone else. By 1986, having taught a variety of
psychology courses, coordinated our interdisciplinary gerontology program,
received research grants, published respectably, and been awarded tenure, I was
ready for a change. Always interested in politics, the APA/AAAS Congressional
Science Fellowship Program seemed like the perfect opportunity to round out my
gerontology expertise.
The Congressional Fellowship was a tremendous experience. Working with the
now-defunct Select Committee on Aging in the House of Representatives, I
networked in gerontology, developed mental health amendments to the Older
Americans Act, became conversant about health policy, and learned more than I
could imagine about the federal budget. I drafted statements for the Congressional
Record, wrote press releases, formulated a three-pronged initiative to
enhance elderly mental health, and ghost-authored an American Psychologist
article for my boss.
In spite of its rewards, however, the harried life of a congressional staffer
seemed too unpredictable for me to maintain over the long term. I returned to
academia in search of a "normal" life, but soon found myself unhappy
and missing day-to-day involvement in national issues. Moreover, the
congressional experience led to the realization that my training as a
psychologist had equipped me with analytical skills that could be applied to a
wide range of interesting and challenging work.
Then luck intervened. One afternoon in June 1989, I received an unexpected
call from OPRR, which enforces the Department of Health and Human Services (HHS)
Regulations for the Protection of Human Subjects. Someone in OPRR had identified
me as an experienced Institutional Review Board (IRB) Chair who might be
interested in a job in Washington, DC.
OPRR's Division of Human Subject Protections performs three statutory
functions: providing guidance on ethical issues in human subject research;
negotiating written commitments (called "Assurances") from
institutions to establish appropriate protections for human subjects; and
exercising oversight to ensure compliance with human subject protection
requirements.
I have found this work to be infinitely challenging and stimulating. For many
years, I was the only behavioral scientist in OPRR, so I became the resident
expert for questions involving behavioral research. It has been especially
rewarding for me to help behavioral scientists understand regulations that may
seem complex and oriented toward biomedical research, and to help biomedical
scientists understand how the regulations should be applied in behavioral
contexts. Sometimes it helps simply to point out that IRBs reviewing behavioral
research must (by regulation) include the expertise needed to review behavioral
research fairly.
The greatest challenge for me, and the greatest reward, has been the struggle
to weigh appropriately the primacy of protecting individual human subjects from
physical and dignitary harm against the potentially critical benefits to society
of cutting-edge research.
Over the years, my OPRR colleagues and I have been faced with making
difficult (and controversial) determinations about such issues as the adequacy
of informed consent for schizophrenia research; revising the regulations
governing pregnant women and fetuses in research; the ethical propriety of AIDS
vaccine research and HIV vertical transmission research in economically deprived
countries; the appropriateness of fenfluramine challenge designs in psychiatric
research involving children; and the ethical, legal, and regulatory
ramifications of surreptitious egg and embryo "swapping" by nationally
recognized fertility researchers (now convicted on federal felony charges). I
have twice been called before congressional committees to explain OPRR's
determinations concerning politically charged issues (informed consent in
tamoxifen breast cancer research, and the shutdown of research at a large
Veterans Affairs Medical Center).
Within the next few months, OPRR will be moving from its position within the
National Institutes of Health to the Office of the Secretary of HHS. From this
more lofty and visible perch, OPRR will be able to exercise greater leadership
within HHS and among the other federal agencies conducting human subject
research. A new National Advisory Committee will be created to help OPRR address
the most complex ethical and policy issues that have, up to now, been beyond
OPRR's expertise. These changes promise to be invigorating, if somewhat
daunting.
In short, I could not imagine a more fascinating and rewarding professional
endeavor. I love my job, and look forward every day to the never ending
challenges that it presents. •
(Originally published in the January/February 1998 issue of Psychological
Science Agenda, the newsletter of the APA Science Directorate.)
More Interesting
Careers in Psychology....
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