With respect to the ethical treatment of research participants, current U.S. regulations require that Institutional  Review  Boards (IRBs) determine that a research design is such that "risks to subjects are reasonable in relation to anticipated benefits, if any, to subjects, and the importance of the knowledge that may reasonably  be  expected  to  result"  (45  CFR  46.111(a)(2)).  However, although the federal regulations do not require IRBs to review the scientific merit of a research design, research with a scientifically flawed methodology will not generate valid or reliable data or produce generalizable and beneficial knowledge. In such cases, it is the participants in the research who will incur the risks, inconveniences, or discomforts that might be involved. Because it would be wrong to put people at risk or even to inconvenience or discomfort them through participation in a poorly designed study, the scientific merit of research becomes an ethical issue (OPRR 1993). Therefore, the National Bioethics Advisory Commission (NBAC) believes that IRBs should assure themselves of both the ethical and scientific merits of the protocols they review.  The Commission is not proposing that IRBs become responsible for conducting scientific peer review (as they may lack specific expertise, and in most instances the proposed studies of research sponsors must undergo independent scientific review)—but only that IRBs have confidence that a study has scientific merit.1

   Even when a clinical trial uses a scientifically sound research design and addresses important questions, conducting the proposed research might be unethical if it would result in the violation of certain ethical principles.  However, because determining the appropriate design for a clinical trial depends on various contextual considerations, what might be an ethically acceptable design in one situation could be problematic in another. For example, it might be unethical to conduct a clinical trial for a health condition in a country where that condition is unlikely to be found, but the same trial might be appropriately conducted where the results could be important to the local population. A more challenging question is whether a research design that could not be ethically implemented in the sponsoring country could be ethically justified in a host country when the health problem that the research is addressing is common to both countries.

   It may be useful to classify international collaborative research projects in developed and developing countries on a continuum. At one end of the continuum is research that has no practical relevance to the health needs of the host country, but is important to the foreign sponsor or researcher. At the other end of the spectrum is research that is directly relevant to the health concerns of the host country, but not to sponsors or researchers. These two extremes illustrate how situations can differ starkly, particularly regarding the potential for exploiting research participants in the host country. An assessment of the ethical  appropriateness of a particular study's design should include an evaluation of where it lies along this continuum. It is worth noting that in an NBAC survey of U.S. researchers, 40 percent of those surveyed said that the research priorities of their funding agencies were incongruent with the top priorities of the developing country in which they were conducting research. Indeed, the relevance of the proposed research to the host country was questioned by U.S. IRBs in 30 percent of the cases reported and by host country ethics review committees in 23 percent of the cases. At the same time, a majority (73 percent) of U.S. researchers surveyed said that their interest in addressing global inequalities in health motivated them to work in a developing country.2

   This chapter focuses on the ethical requirement of choosing a research design that minimizes the risk of harm to human participants in clinical trials and that does not exploit them (which raises the question of the obligations of sponsors and researchers to the research participants during the trial). Chapter 4 discusses the broader question of what obligation, if any, sponsors and researchers have to the participants and others in a host country after a research trial is completed. Following are some of the chief considerations with respect to both research design and ethical obligations owed to research participants:

• whether the research is responsive to the health needs of the host country;
• whether a study design is appropriate for answering the primary research question;
• whether an effective treatment already exists for the condition that is the focus of the study;
• whether the condition for which a new intervention is sought is severe or life threatening;
• the probability and magnitude of any harm that might come to participants in both the experimental and control arms of a given study;
• the probability and magnitude of benefits that may accrue to the study participants;
• the balance of the risks to the participants and the probable benefits to the participants and to others; and
• the future availability of the experimental intervention, if proven effective, to participants and others in the host country after the trial.

Because the choice of a study design for any particular trial depends on these and other factors, it would be inappropriate—indeed,  wrong—to  designate  any  one particular study design as ethical for all research situations. Nevertheless, under certain specified conditions, a particular design can be considered ethically preferable.

Recommendation 2.1: Researchers should provide ethics review committees with a thorough justification of the research design to be used, including the procedures to be used to minimize risks to participants.

   Carefully designed and properly conducted clinical trials are recognized as the principal mechanism for testing  new  clinical  interventions,  and,  given  the  rapid advance of biomedical science in recent years, the number of clinical trials is steadily increasing. The results of any clinical trial must be free of bias, which can be caused by flaws in the study design. Bias in clinical trials refers to the tendency of any aspect of the methodology or the interpretation of data to lead to conclusions about the  effects  of  an  intervention  that  are  systematically different from the truth (FDA 1999). Ensuring that the chosen study design avoids various forms of bias and generates data that can answer the scientific questions being asked can be difficult. Fortunately, a significant literature has been developed to address this challenge (Meinert  and  Tonascia  1986;  Sackett  1983;  Spilker 1991).

   From the perspective of the protection of human participants in research, one of the most critical issues in clinical trial design concerns the use and treatment of control groups, which are often an essential component in methodologies used to guard against bias. The main purpose of a control group is to permit investigators to determine whether an observed effect truly is caused by the experimental intervention being tested or whether it is caused by other factors, such as the natural progression of the disease, observer or participant expectations, differences in the baseline condition of subjects, or other treatment (FDA 1999). The experience of an appropriately selected control group lets the investigator know what would have happened to study participants had they not received the test intervention or what would have happened had they received a different treatment that is known to be effective (FDA 1999). (A description of and additional discussion regarding the use of control groups is provided below.)

   This chapter will discuss the following ethical issues involved in evaluating any proposed clinical trial:equipoise; randomization; the nature and treatment of control  groups; the distinction between efficacy and effectiveness studies; and the selection of the participant population and sample size.

Equipoise

   Among the most important ethical and scientific justifications for beginning a clinical trial is the uncertainty about whether the experimental intervention is better than the status quo (which may be an existing treatment or no treatment at all). This state of uncertainty is known as equipoise, and it is a requirement for the ethical conduct of a clinical trial. Equipoise has been defined as the point at which a rational, informed person would have no preference between two (or more) available treatments (Lilford and Jackson 1995). It is a state in which honest professional disagreement exists among experts regarding whether the study intervention or the control is preferred. In the clinical context, the belief that one intervention is superior to others ethically compels the clinician  to  recommend  the  superior  intervention.  Clinicians are justified in recommending different treatments based on their assessment of what will be effective for a particular patient. Often, the preferences of a clinician regarding an intervention and those of the patient are similar in this regard. However, in the research context, individual  preferences  are  replaced  by  the  collective uncertainty of the clinical community. According to this concept of clinical equipoise, a trial is ethical if there is "genuine uncertainty within the expert medical community about the preferred treatment" (Freedman 1987).

Randomization

   The first documented example of a controlled clinical trial was James Lind's experiment in 1747 with 12 sailors with scurvy aboard the H.M.S. Salisbury (Lind 1753). Lind divided the sailors into six groups of two each and compared the effects of providing different nutritional supplements  to  each  group.  The  two  men  who  ate oranges and lemons recovered immediately. Lind concluded that something in the citrus fruit was counteracting the cause of the scurvy, so he gave citrus fruit to all the other men and observed that they too were cured of the disease. Lind's experiment laid the initial groundwork that established the controlled clinical trial as the best method for determining the effects of new therapies.

   The FDA classifies clinical trial control groups into five types: placebo concurrent control, active treatment concurrent  control,  no  treatment  concurrent  control, dose-comparison concurrent control, and external control (FDA 1999). Each type has strengths and weaknesses, depending on the scientific question being asked, the intervention being tested, and the group of participants involved. Therefore, because no one type of control group is ideal in all situations, researchers should choose the one that best answers the scientific question to be addressed and presents the least risk to the participants. Because of their importance, placebo concurrent control and  active  treatment concurrent control trials are described more fully below.

Placebo Concurrent Control

   A placebo is an intervention that physically resembles the intervention being tested, but is inert and not expected to have any pharmacological effect on the condition being treated. Placebo-controlled trials control not only for the placebo effect (changes in a person's physical or mental condition that result from his or her belief that the study is providing an active treatment), but also for changes that arise due to the natural course of the disease; participant or investigator expectations; the use of other therapies; and the subjective elements of a diagnosis or assessment (FDA 1999). By including a placebo group in a clinical trial, the action of the experimental intervention can be distinguished from other confounding factors and from changes that can be attributed purely to the physical or socioeconomic environment.

   For some clinical trials, the decision regarding the appropriateness of using a placebo is not problematic. It is generally accepted that when no established intervention exists to treat or prevent the condition being studied, it is ethically acceptable to give the control group a placebo. This is because in such trials, there is no treatment against which to compare the experimental intervention. Another argument in favor of the use of placebo controls has been made in the context of research conducted in a developing country. Many researchers have contended that the research question must be defined differently in a setting in which health care resources are limited and participants do not have access to established effective treatments outside of the research context. Some have advocated that in these cases, the measurement of absolute efficacy of a new and potentially more affordable and available intervention is a more relevant research question for the host country than the comparison of a new intervention to an established effective treatment already available elsewhere (Levine 1999; Perinatal HIV Intervention Research in Developing Countries Workshop Participants 1999).

   In the United States, there is substantial agreement in the research community that the use of placebos in studies involving severe or life-threatening illnesses when existing treatment could prevent them or delay their progression is ethically suspect.6 The American Medical Association's (AMA's) guidance for the use of placebos states that "protocols that involve conditions causing death or irreversible damage cannot ethically employ a placebo control if alternative treatment would prevent or slow the illness progression….In general, the more severe the consequences and symptoms of the illness under study, the more difficult it will be to justify the use of a placebo control when alternative therapy exists" (AMA 1999). In contrast, most experts agree that the use of a placebo is acceptable if it does not harm the participants and only results in discomfort (Temple 1996). Similarly, guidance  from  the International Conference on Harmonisation (ICH) indicated that with informed consent and appropriate review by an IRB, research participants could be asked to participate in placebo-controlled trials, even if an existing treatment is available, when the only risk from not receiving treatment is discomfort (ICH 1996). In such cases, it is necessary to ensure that the setting is not coercive and that the participants are fully informed about other available therapies and the consequences of delaying treatment (FDA 1999).

   Ethics review committees will rightfully exercise their judgment in assessing research designs that employ a placebo control. However, the Commission believes that there are some studies for which the presumption in favor of active controls simply cannot be overcome.  Although NBAC did not review the protocol, it appears that a recently reported case may serve as example of such a study (see Exhibit 2.3). In addition, as reflected in the recommendations in this report, the study discussed in the exhibit would be unacceptable because it intends to use developing country citizens as research participants while its primary purpose is to develop a drug for market in the United States and other developed countries.

   Yet, there are some who criticize the use of placebo controls even in cases in which risks to participants are low. One argument against the use of placebos is often grounded in the Declaration of Helsinki: Ethical Principles for Medical Research Involving Human Subjects, which states that "[i]n any medical study every patient—including those of a control group, if any—should be assured of the best proven diagnostic and therapeutic method" (WMA 1964, as amended in 1989). Giving research participants a placebo in place of an established effective treatment deprives them of the "best proven diagnostic and therapeutic method" (WMA 1964, as amended in 1989). Moreover, some critics argue that 1) research participants should not face unnecessary pain or disease resulting from  a  medical  experiment  (Rothman  and  Michels 1994); 2) using a placebo instead of an established effective treatment knowingly breaches researchers' duty to minimize harm (Levine 1998); and 3) it is unethical for individual investigators to enroll patients in a study in which some participants are expected to do even slightly worse than others (Barinaga 1988).

Active Treatment Concurrent Control

   Although placebos are a frequently used control for clinical trials, it is increasingly commonplace to compare an experimental intervention to an existing established effective treatment. These types of studies are called active-control (or positive control) studies, which can take two forms—a superiority trial, in which the question is whether the new drug will be superior to the active control, and an equivalence (noninferiority) trial, in which the question is whether the new drug will be equivalent to but  not  inferior  to  the  active  control  (Hauck  and Anderson  1999).  Active-controlled  trials  are  often extremely useful in cases in which it would be unethical to give participants a placebo because doing so would pose undue risk to their health or well-being.

   One view pertinent to this dilemma was expressed to the Commission in the following way: It is unethical to provide members of a control group with an established effective treatment if that treatment is unavailable in the country where the research is conducted. This is because the opportunity to obtain this treatment would render the choice to enroll in the study irresistible, as those receiving the treatment are unlikely to be able to get it once the trial is over.10 The Commission does not agree with this proposition, because cases exist in which trials using the established effective treatment as a control would generate valuable information that is responsive to the health needs of the host country.

   Some might argue that researchers and sponsors are under no ethical obligation to provide members of a control  group  with  an  established  effective  treatment  if that treatment is unavailable in the country in which the research is conducted. This position maintains that the researchers' and sponsors' obligations to participants do not go beyond providing treatments that are routinely available to the majority of people in the host country.  Still others might contend that researchers and sponsors have an obligation to provide members of a control group with an established effective treatment even if that treatment is unavailable in the host country. Supporters of this view assert that a special relationship is created when sponsors and investigators from a developed country enter a developing country to conduct research. For many, these obligations arise regardless of the prevailing situation in a particular location or country.

   A description of the obligations that arise from these situations can be found in the basic principles of research ethics presented in the Belmont Report: Ethical Principles and Guidelines for the Protection of Human Subjects of Research (National Commission 1979) and many other national and international guidelines. For example, the most straightforward interpretation of the principle of beneficence—to "maximize possible benefits and minimize possible harms"—is that sponsors and investigators should make an established effective treatment available whether or not it is routinely available, because providing the treatment to the control group would maximize possible benefits and minimize possible harms to that group. Therefore, assuming that the sponsoring agency or organization can provide an established effective treatment and that the host country's collaborators, ethics review committee, and ministry of health or other appropriate authority are willing to accept the established effective treatment as part of a randomized controlled trial, a presumption should exist to provide members of a control group with an established effective treatment whether or not that treatment is available in the host country.

   Determining the most useful and ethical research design depends on several factors particular to the circumstances, and one can expect a certain amount of disagreement in this area. Perhaps the best answer for now is to say that investigators must carefully explain and ethics review committees must carefully scrutinize the justification for the selection of the research design, including the level of care provided to the control group. If in a proposed clinical trial the control group will receive less care than would be available under ideal circumstances, the burden on the investigator to justify the design should be heavier. Furthermore, representatives of the host country, including scientists, public officials, and persons with the condition under study, should have a strong voice in determining whether a proposed trial is appropriate. This view is reflected in certain  national  and  international  guidelines  (see Appendix B) and has been advocated by others as well (Benatar and Singer 2000).

Established Effective Treatment and Best Current Methods

   Chapter 1 provided NBAC's rationale for adopting the term an established effective treatment and indicated that this phrase refers to a treatment or a group of treatments that has achieved widespread acceptance by the medical profession (established) and that is as successful as any in treating the disease or condition anywhere in the world (effective). The treatment is not limited to what is routinely available in the host country. The Commission concluded that the standard of an established effective treatment best conveys what is owed to research participants during a trial.

   NBAC recognizes that although it can be difficult to determine whether an intervention constitutes an established effective treatment, this term has certain advantages. Among the difficulties noted, however, was the possible disagreement of some scientists about whether an intervention shown to be effective in one population is likely to be as effective in another population that differs in significant ways. By choosing the term an established effective treatment and avoiding the qualifier best, NBAC proposes, simply, that the selection of an established effective treatment in a clinical trial conducted in a developing country must be made on a case-by-case basis.

   The Commission also believes that this approach would satisfy those who have criticized the best proven method standard, or the established effective treatment standard proposed here, by arguing that the use of complex and very expensive medical care (such as surgery or catheterization for cardiovascular disease) in a developing country often is not feasible, even within the context of most research studies, and that such care is not sustainable after the research is complete. These commentators allege that if complex and costly medical care is used as the control against which new interventions are measured, research studies will generate data that potentially will be irrelevant to the host country—an argument analogous to that used to defend placebo use.

   As noted in the discussion of placebo use, three factors must be considered by researchers when designing a study and by ethics review committees when reviewing protocols if they are to assess the level of medical care that should be provided to participants: 1) the well-being of the study participants; 2) the relevance of the research question to the host country; and 3) the feasibility of implementing a given type of medical care in the host country setting. In the case of medical treatments that involve a huge medical infrastructure or that are extremely costly to implement, feasibility may be the determining factor. In addition to feasibility, the ethical assessment of what level of care to provide often will depend on balancing the concern for the well-being of study participants with concern for the relevance of the research question to the host country. NBAC believes that researchers and ethics committees must find a balance between these important ethical demands in each research project.

Recommendation 2.2: Researchers and sponsors should design clinical trials that provide members of any control group with an established effective treatment, whether or not such treatment is available in the host country. Any study that would not provide the control group with an established effective treatment should include a justification for using an alternative design. Ethics review committees must assess the justification provided, including the risks to participants, and the overall ethical acceptability of the research design.

   Efficacy clinical trials are sometimes considered optimal care studies in which the research question is whether the experimental treatment works under ideal conditions. In contrast, effectiveness  clinical trials ask whether the experimental treatment works under ordinary circumstances. Often, there are legitimate differences of opinion regarding whether an efficacy trial or an effectiveness  trial  is  more  scientifically  and  ethically appropriate in a given situation. On the one hand, efficacy trials ignore problems of access to care, generalizability from a highly selective sample of patients and physicians, and adherence to regimens, for example. If an efficacy trial is negative, it is hard to imagine that an effectiveness trial would show a benefit; therefore, effectiveness trials might have limited usefulness in developing countries. If an efficacy trial is productive, the question regarding whether the intervention will be effective when used by a broader range of doctors and patients, who may not find it affordable, accessible, or acceptable, is still open. On the other hand, a problem with effectiveness trials is that if they produce a negative result, it is unclear whether the experimental intervention would fail under any circumstances, or only because patients and doctors lacked access to it, or because the doctors were unskilled or the patients poorly adherent.

   In an efficacy trial, the control group should receive the best established treatment. However, in an effectiveness  trial,  the  research  question  cannot  always  be answered by giving the control group the best established treatment. No consensus has emerged that the research questions posed in efficacy trials would be as pertinent to the needs of a host country as would the research questions posed in effectiveness trials. To provide the best established  treatment  would  be  to  ask  a  completely different research question, one that may not be relevant to the clinical needs of the population being studied.

   Another important study design issue is the selection of the population to be studied. In the early phases of drug development, for example, research participants are selected from a small subgroup of the patient population in which the drug eventually may be used (CPMP 1995).  This is done to maximize the opportunity to observe specific clinical effects of interest. By the time the experimental intervention enters pivotal Phase III trials, the participants should more closely mirror the intended users. Therefore, in these trials the criteria for selecting participants usually are relaxed as much as possible, without  jeopardizing  the  possibility  of  conducting  a successful trial. However, even a Phase III clinical trial usually is not completely representative of future users, because of several factors, including the geographical location of the trial, when it is conducted, and the medical practices of the investigators and clinics involved (CPMP 1995). Multicenter trials help to reduce the influence of such factors; however, if a multicenter trial is not feasible, every effort should be made to reduce the variations that can be caused by these factors.

   Determining the sample size is another important component of clinical trial planning. Appropriate sample size depends on the design of the trial and its primary objective. Many methods and statistical models have been developed to calculate appropriate sample size.  However, the number of participants in a clinical trial always should be large enough (but no larger than necessary) to provide a reliable answer to the questions posed. 

   The Joint United Nations Programme on HIV/AIDS (UNAIDS), for example, has since its inception in the mid-1990s promoted the involvement of local communities and prospective research participants in the design and implementation of research studies. UNAIDS has an  Ethical  Review  Committee—the duties of which include the  basic IRB function of ethical review of research  protocols—and  this  committee's  standard assessment form includes a section entitled "Community Involvement and Impact." The following questions are included in this section:

   In  anticipation  of  the  initiation  of  an  increasing number of HIV/AIDS preventive vaccine trials, UNAIDS issued a guidance document in February 2000, in which Guidance Point 5 recommends the following:

To ensure the ethical and scientific quality of proposed research, its relevance to the affected community, and its acceptance by the affected community, community representatives should be involved in an early and sustained manner in the design, development, implementation, and distribution of results of HIV vaccine research (UNAIDS 2000, 19).

   However, it is frequently difficult to define the relevant community of participants, no matter where the research is conducted. In cases in which no traditional community structure exists, local organizations or non-governmental organizations often can assist in representing the interests of participants in the research process. A research project might involve participants from widely scattered communities—sometimes in several nations—and it might be logistically difficult to reach representatives of every location from which participants are drawn.  In addition, in some communities social hierarchies or corrupt elements exist that might impede the consideration of research participants' interests; therefore, in each research setting, it is necessary to determine the most appropriate way to involve local representatives who can provide a voice for research participants.

Recommendation 2.3: Researchers and sponsors should involve representatives of the community of potential participants throughout the design and implementation of research projects. Researchers should describe in their proposed protocol how this will be done, and ethics review committees should review the appropriateness of this process. When community representatives will not be involved, the protocol presented to the ethics committee should justify why such involvement is not possible or relevant.
 

Monitoring the Interim Results of a Study

   Randomized  clinical  trials  begin  at  a  point  of equipoise regarding the relative risks and benefits of the intervention being evaluated. As the study proceeds, however, cumulative data or recent findings from other research efforts may provide strong evidence in favor of one of the interventions being tested, thus overturning the equipoise and suggesting that the study should be stopped. Responsibility for the review of interim data is often given to an independent group, such as a Data and Safety Monitoring Board (DSMB), with expertise in the clinical problem, biostatistics, and bioethics. DSMBs have confidential access to interim results, which are not available to investigators or sponsors. Unblinding investigators and sponsors would introduce bias into the trial and undermine its integrity. The goal of interim analysis is to stop the trial early if the superiority or inferiority of the  experimental intervention being tested has been clearly established, if it is evident that the experimental intervention has no efficacy, or if unacceptable adverse effects are occurring (CPMP 1995; DeMets et al. 1999).

   In addition to examining the evolving results of the trial, groups that are conducting interim analysis should be aware of advances in the field and assess whether study designs remain ethically and scientifically valid. This is especially important for studies that involve diseases for which rapid progress in the development of effective therapies has occurred. For example, trials in which the control group receives an established effective treatment may be deemed unethical because a new treatment has been found that is clearly more effective. In addition, trials may no longer be considered ethical because they have no reasonable hope of leading to an unequivocal result, or they have already demonstrated a statistically definitive and clinically significant difference between the control group and the experimental arm. Trials that are deemed to be unethical should be terminated to protect the research participants, even if continuation of the research would be of interest to the medical and scientific communities. Because clinical trials often require several years to complete, it is important to monitor them regularly to safeguard the best interests of the participants.

Repeating a Study

   A different situation arises when a treatment has been shown to be effective in a developed country and researchers propose to repeat the study in a developing country. What could justify repeating a study using the same research design? Several who provided comments to NBAC remarked that generally, an accumulation of evidence from many studies is needed in order to establish a new intervention as efficacious and to warrant changes in health policy or medical practice. Whether several studies of the same intervention constitute repetition or whether conditions or protocols among studies are different enough that genuinely new evidence is being collected may not be known until all of the data are examined. Dispute frequently occurs, even in the United States, about whether differences in study populations—such as race, sex, stage of disease, presence of other conditions,  or   environmental  conditions—constitute scientific differences that necessitate further empirical research because they might have a material effect on the effectiveness of an intervention.16 In principle, if there is no scientific reason to question the effectiveness of the new treatment in the developing country population, it would  be  ethically  problematic  to  repeat  the  study.  However, in practice, as mentioned above, it may be difficult to determine when valid reasons to repeat a study exist. In some cases, because different biological, social, and  environmental  conditions  are  found  in  different developing countries, new interventions must be studied in those countries to determine their effectiveness in those settings. In other cases it may be reasonable to presume that treatments that are recognized to be effective based on data from the United States or other developed countries do not need to be studied in every country in which they are used.

2 See Kass, N., and A. Hyder, "Attitudes and Experiences of U.S. and Developing Country Investigators Regarding U.S. Human Subjects Regulations," 49—50. This background paper was prepared for NBAC and is available in Volume II of this report.

3 Goodman, S., Public comment submitted to NBAC. November 13, 2000.

4 Dickersin, K., Testimony before NBAC. December 2, 1999.  Baltimore, Maryland.

5 Temple, R., Testimony before NBAC. September 18, 1997.  Bethesda, Maryland. Meeting transcript, 7—8.

6 AMA, Public comment submitted to NBAC. Received November 15, 2000; FDA, Public comment submitted to NBAC. Received November 9, 2000; Temple, R., Public comment submitted to NBAC. Received November 13, 2000.

7 Temple, R., Public comment submitted to NBAC. Received November 13, 2000.

8 Temple, R., Testimony before NBAC. September 18, 1997. Bethesda, Maryland.

9 See Kass and Hyder, 53.

10 Sommer, A., Testimony before NBAC. September 16, 1999. Arlington, Virginia. Meeting transcript, 189.

11 See Kass and Hyder, 53.

12 Goodman, S., Public comment submitted to NBAC.  November 13, 2000.

14 UNAIDS, Ethical Review Committee. Assessment Form for Committee Review. Question 9.

15 Ibid., Question 10.

16 Bennish, M., Public comment submitted to NBAC. Received November 12, 2000; Goodman, S., Public comment submitted to NBAC. Received November 13, 2000.

17 Sommer, A., Testimony before NBAC. September 16, 1999.  Arlington, Virginia. Meeting transcript, 179—180, 188—189, 215—218. 

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