Thread by @littleann4ever

1/ So, remember BC studies w/waived ethics co-authored by #DrHenry? Well, I looked into BCPH Act re:Emerg Powers & to summarize:
#DrHenry still believes #COVID19 is significant risk as "infectious/hazardous agent" w/serious PH impact but she wants you to forget all that.#bcpoli

2/ Let me explain. So, as per the PH Act, Part 5-Emerg Powers, sec 53: “During an emerg, this Part applies despite any provision of this or any other enactment, incl "the collection, use or disclosure of personal info..." #bcpoli bclaws.gov.bc.ca/civix/document…

3/ This above section may just provides a convenient cherry-picking opportunity to justify no participant consent in these studies, but in order for this section to apply, there must be a BCPH Emergency declared, stipulating serious risk to PH. #bcpoli

4/ And yes, as declared by #DrHenry on Mar17/20, #COVID19 is still very much an ongoing PH Emerg in BC as per this notice with provisions under Part 5 -Emerg Powers, Sec 52 (2) of BCPH Act. #bcpoli www2.gov.bc.ca/assets/gov/hea…

5/ These provisions state Emerg powers are in effect only if PHO believes at least 2 of these:(a) the regional event could have serious PH impact;(b) it's unusual/unexpected;(c) there's significant risk of spread of infectious/hazardous agent;(d) there's risk of travel.”#bcpoli

6/ As it happens, all 4 criteria above are cited as still existing in BC re: #DrHenry’s current regional PH Emerg declaration & yet, according to the latest @BCGovNews update re: PH safety measures, all “Province-wide restrictions have lifted.” #bcpoli www2.gov.bc.ca/gov/content/co…

7/ Q:Are the all-encompassing PHO emerg powers & applicable risk criteria that must exist for these powers to be in effect a package deal? If yes, then where are regional safety policies to protect public from “serious impacts”&“significant risks” defined in this PH emerg?#bcpoli

8/ PH Emerg cherry-picking to cut corners on these studies, is perhaps also being capitalized on in Tri-Council Policy Stmt: Ethical Conduct for Research Involving Humans (TCPS-2) Ch 6, Sec D. "Research Ethics Review during Publicly Declared Emergencies: ethics.gc.ca/eng/tcps2-eptc…

9/ The above sec states: “It should be noted that the following articles & requirement for consent will not apply to PH activities undertaken by federal, provincial & territorial PH officials operating under statutory powers during publicly declared health emergencies.”#bcpoli

10/But sec also says, “given the extraordinary circumstances participants are potentially subjected to in publicly declared emerg, special attention s/b given to upholding core principles of Respect for Persons/Concern for Welfare & Justice when reviewing research ethics"#bcpoli

11/ In fact re: same TCPS-2 sec: any “exceptions to or infringements of ethics principles & REB procedures, s/b narrowly tailored…such that they rely on the most restrictive or least intrusive means necessary to the promotion & guidance of ethical conduct in research." #bcpoli

12/ con't: "This approach – consistent w/international bioethics human rights norms – maximizes respect for ethical principles & helps to ensure that exceptions & the means to implement them are not unduly broad, overreaching or unjustifiably invasive.” #bcpoli

13/ In summary, this sec also stipulates that “REBs & researchers s/b aware that individuals, prospective participants, researchers & institutions may not normally be considered vulnerable, but may become so by very nature of public emergency." #bcpoli

14/con't "Those already vulnerable may become acutely so” &“⬆️public risks & devastation that cause public emerg to be declared can threaten welfare or safety. Taking this into consideration, REBs & researchers should ensure..provisions for greater than normal attention to risk.”

15/ So as per everything stated above & circling back to the very explicit PH risk criteria that must be present & declared by a PHO to enable a PH Emergency & by extension, grant the PHO far-reaching powers that can influence research processes-I have 2 loaded questions: #bcpoli

16) Q #1: While studies took place, was “transmission of infectious agent known as SARS-CoV-2 which caused cases & outbreaks of serious illness known as #COVID19 among BC population” (re:#DrHenry’s PH Emerg notice) properly mitigated to⬇️prov-wide illness/hosp/deaths?” #bcpoli

17/ Q #2: Since significant public risks still existed while these studies were ongoing (as declared by #DrHenry enabling a PH Emerg) & fact that the public were potentially made even more vulnerable (re:TCPS-2), how could ethics reviews be waived for all these studies? #bcpoli

18/ Thanks for reading! My primary goal right now, is to put all this out there. And for the record, I've also added this information to my existing "Made in BC" Research Ethics BC & Covid-19" document. ⬇️
docs.google.com/document/d/1Ab…

*provide!