Tag: informed consent

  • Mastering Clinical Research and Career Growth in a Rapidly Changing Industry

    Mastering Clinical Research and Career Growth in a Rapidly Changing Industry

    Alec Spinelli – an Author and Educator

    Table of Contents


    Tell us about your background and your motivation behind writing these series of books.

    Alec Spinelli is a seasoned Clinical Research Author, Clinical Project Manager, Clinical Educator and Speaker with nearly 20 years of clinical research industry experience and 26 years in healthcare. He has led global trials across Phases Iโ€“IV and held key roles at sponsor and CRO companies, including Sr. CRA, Lead CRA, Clinical Trial Manager,  Clinical Team Lead, and Project Manager. He is currently a Start-up Project Manager at Fortrea CRO.

    Alec holds an MBA in Business Management from Liberty University, completed his graduate studies in Biomedical Engineering at Rutgers University, and earned a B.A. in Biology. His blend of hands-on experience, academic insight, and investment in continuing education make his books an essential resource to understanding and navigating clinical research for patients, families, and clinical research professionals at all levels.

    My motivation for writing my clinical research book series came from years of answering questions from colleagues and LinkedIn connections about career growth, ICH-GCP, regulatory compliance, and clinical trial operations. I wanted to create practical, concise resources that simplify complex topics and help professionals confidently navigate and advance within clinical research.

    You can see all current books available for purchase on Amazon:

    Amazon.com: Regulatory Affairs in Global Clinical Research : A Comprehensive Look at FDA, EMA, PMDA, MHRA, and Other Global Regulatory Pathways for Trials and Submissions eBook : Spinelli, Alec: Kindle Store

    Amazon.com: ICH – GCP E6(R3) Comprehensive Resource Guide for Clinical Research Professionals: Practical Insights and Key Updates for Clinical Study Design and Application eBook : Spinelli, Alec: Kindle Store

    Amazon.com: Informed Consent Made Simple – Forms, Purpose, and Practice in Clinical Research: A Comprehensive Guide to What Patients and Families Need to Know and What Professionals Must Understand eBook : Spinelli, Alec: Kindle Store

    Amazon.com: Mastering Clinical Trials: Essential Knowledge for Clinical Research Professionals : The Comprehensive Reference Manual for Clinical Trial Methodology and Real-World Research Applications eBook : Spinelli, Alec : Kindle Store

    Amazon.com: Institutional Review Board (IRB) Made Simple – the Purpose, Process, and Scope of the IRB in Clinical Research: A Comprehensive Guide to the IRB for Patients, Families and Professionals eBook : Spinelli, Alec: Kindle Store

    Amazon.com: Clinical Research The Best Career You Never Heard Of 10 Reasons to Get Into the Research Industry NOW eBook : Spinelli, Alec: Kindle Store

    Amazon.com: How to Snag that First Clinical Research Job: A Concise Guide for ANYONE to Preparing, Interviewing, and Landing that First Clinical Research Job (How … Research Career Blueprint Book Series 1) eBook : Spinelli, Alec: Kindle Store

    Amazon.com: How to Snag That First Clinical Trial Manager Job: A Concise Guide to Preparing, Interviewing, and Landing that First CTM Job You’re After (How to Snag … Research Career Blueprint Book Series 4) eBook : Spinelli, Alec: Kindle Store

    Amazon.com: How to Snag That First CRA Job 2nd Ed: The Updated Guide to Landing that First CRA Job Youโ€™re After (How to Snag That First – The Clinical Research Career Blueprint Book Series) eBook : Spinelli, Alec: Kindle Store

    Amazon.com: How To Snag That First Senior Clinical Research Associate Job 2nd Ed: The Updated Guide to Landing that First Sr. CRA Job Youโ€™re After (How to Snag That … Research Career Blueprint Book Series 3) eBook : Spinelli, Alec: Kindle Store

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    Why do you think the clinical research industry still has such low visibility despite its enormous impact?

    I think clinical research often carries an air of mystery, making it seem inaccessible to those unfamiliar with the field. Many people have never heard of clinical research or interacted with it until a family member, close friend, or loved one becomes sick and begins exploring treatment options. At that moment, clinical research can suddenly become very personal.

    People also assume it requires a medical degree or years of specialized training, but the truth is far more inclusive. Clinical research welcomes professionals from diverse backgrounds, offering pathways for individuals with experience in healthcare, science, and even nontraditional fields to contribute meaningfully to advancing medicine.

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    Why is it so difficult for candidates to land that first clinical research role?

    One of the fundamental challenges in entering the clinical research field is the competitive nature of the job market. With so many individuals seeking to break into this rewarding profession, it’s essential to differentiate yourself.

    Knowing about the industry is only half the battle. The other half lies in preparation, where developing the skills, gaining the experience, and crafting the narrative you need to make employers see you as a perfect fit.

    From understanding the foundational knowledge required for clinical research roles, including specific therapeutic area, regulatory, start-up, clinical operations, data management, etc., to crafting a resume highlighting your most relevant strengths, and ways to leverage your existing skills, even if your background isn’t directly in clinical research.

    These are factors that must be addressed when seeking to break into a first-time clinical research role.

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    What do hiring managers prioritize versus what applicants think matters in terms of someoneโ€™s CV and skills?

    Many applicants believe hiring managers only focus on certifications, titles, or years of experience, but hiring managers often prioritize quantifiable results, adaptability, communication, reliability, problem-solving, and whether someone can work effectively within cross functional team.

    A strong CV certainly matters, but employers also look for candidates who understand clinical trial operations, can think critically, and demonstrate professionalism. In clinical research especially, attitude, responsiveness, and the ability to learn and adapt quickly can sometimes outweigh having a great background on paper. More recently, hiring managers are also looking for the ability to utilize AI tools and systems effectively to execute trials successfully.

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    What do people misunderstand most about the Clinical Research Associate (CRA) role before entering it?

    I think one of the biggest misunderstandings about the CRA role is that people think it is mostly travel and site visits. Another very frequent misconception is that it is an entry-level position.

    In reality, the CRA role typically requires prior clinical research experience and a strong understanding of monitoring, trial oversight, regulations, and site operations.

    While travel can be a major part of the role, CRAs are also responsible for communication, documentation review, problem-solving, and protecting patient safety and data integrity. Success often depends on organization, adaptability, critical thinking, and the ability to manage complex relationships across multiple studies and sites.

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    What is the biggest mindset shift when moving from CRA to Clinical Trial Manager (CTM)?

    One of the biggest mindset shifts when moving from a CRA to a CTM role is transitioning from primarily overseeing individual tasks and sites to leading the broader strategy and execution of an entire clinical trial.

    A CRA often focuses on monitoring and site-level oversight, while a CTM must think more globally across timelines, budgets, vendors, cross-functional teams, and operational risks. The role requires stronger leadership, communication, and decision-making skills, along with the ability to balance competing priorities while keeping the study moving forward efficiently and compliantly.

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    What do you see as the most important philosophical shift in ICH-GCP E6(R3)?

    I believe the most important philosophical shift in ICH-GCP E6(R3) is the stronger emphasis on Quality by Design (QbD) and proactive risk management rather than relying heavily on retrospective correction and excessive documentation.

    The updated guidance encourages organizations to build quality into clinical trials from the beginning by focusing on critical processes, patient safety, and data integrity.

    It reflects a more modern, flexible, and practical approach to trial oversight that better supports innovation, decentralized trials, technology integration, and real-world operational challenges across global clinical research.

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    I believe informed consent forms (ICFs) have become far too complex for the average patient and even overwhelming for many experienced healthcare professionals.

    While the intent is to protect patients and ensure transparency, many ICFs are now filled with dense legal, medical, and regulatory language that can make true understanding difficult.

    Patients are often reviewing these documents during stressful and emotional moments in their lives. That was one of the main motivations behind writing my book, โ€œInformed Consent Made Simple.โ€ I wanted to create a practical resource that helps patients, families, and professionals better understand the purpose, process, and real-world importance of informed consent in clinical research.

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    How do you think AI will reshape clinical operations over the next five years?

    I believe AI will significantly reshape clinical operations over the next five years by helping augment many routine, simple, and time-consuming tasks.

    AI systems will likely assist with the Trial Master File (TMF) index construction and review, protocol summarization and analysis for site ID, and first-pass QC reviews of essential records, helping reduce administrative burden and improve efficiency.

    Rather than replacing clinical research professionals, I believe the workforce will shift its focus toward more complex responsibilities involving oversight, strategy, decision-making, relationship management, and patient-centered activities that still require strong human judgment and experience.

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    If someone wants to enter clinical research this year, what should they do first?

    If someone wants to enter clinical research this year, the first thing they should do is review the top entry-level research roles and identify which pathway best aligns with their background, interests, strengths, and long-term goals.

    Not every entry point is the same, and understanding where they fit best is critical. Next, they should build a strong foundation in general clinical research knowledge and then focus specifically on the responsibilities and expectations of their desired role.

    This helps them craft a targeted resume that highlights transferable skills, relevant strengths, and how their existing experience can provide value to the company and clinical trial team. They should also ensure they understand use and application of AI in clinical research as this is becoming an increasingly essential skill in our industry.

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    We’d like to thank Alec for sharing his resources and expertise to the S.P.I.R.I.T. community!

  • CORRECTION: HHS FY26 Budget Re-Org Article

    CORRECTION: HHS FY26 Budget Re-Org Article

    Good morning, good afternoon, and good evening, Compliance Rockstars, Clinical Research Professionals, Ethics Enthusiasts, Legal Experts, and Investigators!

    330+ subscribers and counting!

    Authored By: Tasha Mohseni

    I’d like to make a CORRECTION to my recent post.

    The post relates to ICYMI: HHS FY26 Budget Re-Org: Assistant Secretary for Enforcement (ASE). It was my understanding from the House Appropriations Committee press release that the HHS FY26 budget was approved. Under this train of thought, I wrote about how the approved budget would potentially impact the Office of Human Research Protections (OHRP). Specifically, I highlighted the following:

    • The current HHS structure with OHRP under the Office of the Assistant Secretary for Health (OASH)
    • Introduced the Assistant Secretary of Enforcement (ASE)
    • Closed with how I envision OHRP under the new ASE

    I learned that this is NOT the case.

    In fact, the FY26 budget was only approved until January 30, 2026 for most agencies. Research!America issued the following statement:

    โ€œWe want to thank the leaders and members of the House and the Senate appropriations committees for the resolve and hard work so clearly demonstrated by the strong NIH provisions in this package. We are particularly grateful to Senate Labor-HHS Subcommittee Chair Shelley Moore Capito (R-WV), Ranking Member Tammy Baldwin (D-WI), House Subcommittee Chair Robert Aderholt (R-AL), and Ranking Member Rosa DeLauro (D-CT).

    Even in these challenging times, the bill increases the overall NIH budget and includes new protections to help the agency fulfill its lifesaving mission. While cuts to several key research and public health agencies signal that this work is far from over, the legislation is a vast improvement over the devastating cuts included in the presidentโ€™s FY26 budget proposal. We urge Congress to swiftly pass this legislation prior to the Jan. 30 funding deadline.โ€

    How did I end up reporting inaccurate information?

    Remember the infamous government shutdown? Well, when Congress doesn’t approve the agency appropriation bills or a continuing resolution, the government shuts down. During a shutdown, federal agencies must discontinue all nonessential discretionary functions until new funding legislation is passed and signed into law. Only essential services and mandatory spending programs continue to function. The act that ended the government shutdown is known as a continuing resolution. A continuing resolution temporarily funds the government in the absence of full appropriations bills, often by continuing funding levels from the prior year.

    So, now what?

    The house and senate appropriation committees released HHS FY26 bill text (along with other agencies). Upon review of the bill text:

    • There was no mention of OHRP, OASH, or ASE
    • There wasn’t clear language regarding re-organization or consolidation of agencies within HHS

    Though there will be investment into medical research, I can’t help but wonder about the compliance aspect. Rather, I’m concerned about the welfare of research participants as we enter the new year. Perhaps more details will be released (assuming Congress passes these appropriation bills). We will just have to wait and see, but you can guarantee I’ll write about it as soon as I hear anything.

    Thank you for bearing with me as we navigate this complex regulatory landscape!

    I always welcome folks to share information with me if what I’ve reported is incorrect or misunderstood. It is my promise and commitment to you to accurate report scientific and regulatory information.

  • ICYMI: HHS FY26 Budget Re-Org: Assistant Secretary for Enforcement (ASE)

    ICYMI: HHS FY26 Budget Re-Org: Assistant Secretary for Enforcement (ASE)

    Eager to skip ahead to today’s topic?

    Jump to the Table of Contents.

    Good morning, good afternoon, and good evening, Compliance Rockstars, Clinical Research Professionals, Ethics Enthusiasts, Legal Experts, and Investigators!

    330+ subscribers and counting!

    Authored By: Tasha Mohseni

    Why does January always feel so long?

    If you saw my previous blog article, I covered select regulatory updates from HHS and its sub-agencies. There was so much to write about. It was difficult to determine which updates were the most important. So many things occur on a daily basis!

    crop chemist holding in hands molecule model

    It can be easy to miss the bigger picture. This inspired me for today’s topic.

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    Let’s dive right in!

    I’m going to cover the re-organization of the Department of Health and Human Services (HHS) and how how this impacts the Office of Human Research Protections (OHRP). Specifically, I’d like to highlight:

    • The current HHS structure with OHRP under the Office of the Assistant Secretary for Health (OASH)
    • Introduce the Assistant Secretary of Enforcement (ASE)
    • Close with how I envision OHRP under the new ASE

    As a general reminder, any legal information discussed within this post should be discussed with your institution.

    Table of Contents:


    What is OASH?

    The Office of the Assistant Secretary of Health (OASH) develops policy recommendations for public health across HHS and its agencies. OASH is tasked with improving the health and well-being of Americans by leading on policy, practices, and programs. OASH seeks to restore scientific integrity and transparency to rebuild public trust and advance the public good. Below is the current organizational structure:

    OHRP is one of these divisions that supports OASH.

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    What is OHRP?

    OHRP fulfills responsibilities set forth in the Public Health Service (PHS) Act including:

    • Providing leadership for human research subjects protections within HHS and for the U.S. Government in cooperation with other Federal Agencies
    • Developing and monitoring as well as exercising compliance oversight relative to HHS regulations for the protection of human subjects in research conducted or supported by any component of HHS
    • Promoting and coordinating appropriate HHS regulations, policies, and procedures both within HHS and in coordination with other Departments and Agencies in the Federal Government
    • Establishing criteria for approval of assurances of compliance for the protection of human subjects with both domestic and foreign institutions engaged in HHS-conducted or supported research involving human subjects
    • Conducting programs of clarification and guidance for both the Federal and non-Federal sectors with respect to the involvement of humans in research; and directing the development and implementation of educational and instructional programs and generating educational resource materials
    • Evaluating the effectiveness of HHS policies and programs for the protection of human subjects
    • Serving as the liaison to Presidential, Departmental, Congressional, interagency, non-governmental, and international commissions and boards to examine ethical issues in medicine and research and exercises leadership in identifying and addressing such ethical issues
    • Promoting the development of approaches to enhance and improve methods, particularly quality improvement at the institutional level, to avoid unwarranted risks to humans participating as subjects in research covered by applicable statutes

    OHRP is comprised of multiple subparts, including the formerly terminated Secretaryโ€™s Advisory Committee on Human Research Protections (SACHRP).

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    What is ASE?

    To quickly bring you up to speed:

    • In March 2025, HHS announced a new initiative, Make America Healthy Again, in response to Executive Order (EO) 14210 “Implementing the President’s โ€œDepartment of Government Efficiencyโ€ Workforce Optimization Initiative”
      • The EO was issued in February 2025
      • Within this initiative, the Assistant Secretary for Enforcement (ASE) is introduced: “HHS will create a new Assistant Secretary for Enforcement to oversee the Departmental Appeals Board (DAB), Office of Medicare Hearings and Appeals (OMHA), and Office for Civil Rights (OCR) to combat waste, fraud, and abuse in federal health programs.”
    • Then, in September 2025, the House Appropriations Committee approved the HHS FY26 budget (including the creation of ASE and re-organization within HHS)

    Now that we have some background information, let’s talk about ASE.

    Directly from the HHS FY26 budget justification, ASE will centralize executive oversight over several mission-critical offices:

    • Departmental Appeals Board (DAB)
    • Office for Civil Rights (OCR)
    • Office of Medicare Hearings and Appeals (OMHA)
    • Office for Human Research Protections (OHRP)

    This consolidation is designed to streamline oversight, improve enforcement and adjudication coordination, provide education and guidance on relevant legal authorities, and strengthen HHS’s ability to fulfill its legal obligations to the public. ASE will:

    • Ensure individuals and institutions attain resolution of complaints, disputes, and appeals
    • Encourage compliance through regulations, guidance, education, and technical assistance
    • Enforce legal compliance and adjudication under federal statutes and regulations

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    A Grim Future for OHRP Under ASE

    As someone with an accounting and program management background, I can appreciate cutting costs. Having said that…

    Cost reduction should NOT equal mission reduction.

    OHRP’s mission will take an even bigger blow.

    I was alarmed when I didn’t see OHRP mentioned in the HHS press release or fact sheet.

    In the press release, it was indicated that ASE would be comprised of DAB, OMHA, and OCR. Further, it was noted in the fact sheet that “A new Administration for a Healthy America (AHA) will consolidate the OASH, HRSA, SAMHSA, ATSDR, and NIOSH, so as to more efficiently coordinate chronic care and disease prevention programs and harmonize health resources to low-income Americans.” This made me wonder…where is OHRP in the midst of this?

    Reviewing OHRP’s approved budget is an even sadder story.

    I did feel some relief once I saw OHRP was mentioned within the HHS FY26 budget justification. However, it slowly disappeared as I read through the budget requests for each unit. HHS signaled where OHRP falls on the totem pole. Directly copied from the budget justification:

    “The Office for Human Research Protection also requests non-trust fund budget authority that will maintain minimal operations. This includes conducting a limited number of for-cause compliance assessments of human research protection programs or institutional review boards, processing approximately 800-1,000 incident reports, and approximately 400-600 complaints about research. Develop guidance, the fulfillment of the FWA and IRB registration missions, and the ability to develop educational tools and resources will be limited.”

    OHRP already had limited staff and resources with great responsibility. How is OHRP supposed to act on their duties under the PHS Act when the budget request is so specific? I have so many questions about this budget request:

    1. What is considered a “limited number” of for-cause compliance assessments?
    2. How is OHRP supposed to prioritize which HRPPs and IRBs receive such assessments?
    3. What happens if there’s more complaints and/or incidents than originally projected?
    4. Why are resources (i.e., educational tools) and enforcement mechanisms (i.e., FWA) that uphold public trust in research on the back burner?

    OHRP is going to need support and expertise from research compliance professionals such as ourselves for education and guidance development. NACHRP and PRIM&R could potential lead such efforts.

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    I hope you found this article insightful!

  • Why Ethics Matters: Open FDA Investigation on Alleged Non-Consensual Human Experimentation

    Why Ethics Matters: Open FDA Investigation on Alleged Non-Consensual Human Experimentation

    See: Followup: Open FDA Investigation on Alleged Non-Consensual Human Experimentation

    RD Research Services Current Way of Thinking as of 10/30/25

    Eager to skip ahead to today’s content?

    Jump to the Table of Contents.

    Good morning, good afternoon, and good evening, Compliance Rockstars, Clinical Research Professionals, Ethics Enthusiasts, Legal Experts, and Investigators!

    330+ subscribers and counting!

    Authored By: Tasha Mohseni

    It feels so good to be writing, reporting, and sharing my insights with you all again!

    I have a fun fact to share that you may not have known about me. When I was in high school I always thought I would be a journalist. I *almost* wish I pursued that, but I’m glad I didn’t. I only pictured myself as the type of journalist that would be present during a high-stakes car chase. Or maybe even being at the front lines of a natural disaster. Another fun fact about me is that I always wanted to be a blogger. But…I never knew what I would write about. I just knew I wanted to write something meaningful…and useful.

    a woman reporting beside the van

    I had no idea that I could report the type of regulatory updates I do now. Without having gone through what I’ve gone through, I never would have ended up in research compliance. And without this journey, I never would have created this meaning AND useful blog for professionals in our field.

    Speaking of our field, can you think of a recent human research ethics violation? If you know of a recent event, please leave a comment and share a link to promote discussion!

    Leave a Reply

    I tried to think about this some time ago (I want to say last month). Of course I am familiar with the cases that led to the Belmont Report. And I certainly recall some after the Belmont report (e.g., Jesse Gelsinger). Fast forward to last Wednesday. I was browsing Regulations.gov, which is still in operation despite the government shutdown. You can imagine my surprise when I came across the following docket:

    Screenshot from Regulations.gov RE: FDA nonrulemaking docket.

    When I read this, I thought "WHOA!" I couldn't believe my eyes. This sounds to me like a recent human research ethics violation case. Which leads me to today's topic. Today, I'm going to cover this request for an FDA investigation. Specifically, I will:

    • Introduce the case prompting investigation
    • Share my thoughts on which ethical tenets were violated based on the intial petition
    • Review the remaining documents associated with this docket
    • Close the article with my concluding thoughts

    As a general reminder, these are my own interpretations. Any legal information discussed within this post should be discussed with your institution.

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    Table of Contents:

    1. Citizen Petition from Kimberly C. Tanner
    2. Initial Ethical Analysis
      1. Nuremberg Code
      2. Belmont Report
      3. ICH GCP E6(R3)
      4. Declaration of Helsinki
    3. Review of Remaining Documentation within the FDA Docket
      1. The "Good Science" Article
      2. The Legal Dagger
      3. The Coup De Gras
    4. Closing Thoughts

    Citizen Petition from Kimberly C. Tanner

    This can be reviewed under FDA-2025-P-5514-0001.

    In summary, the petition states:

    • The FDA to complete the following actions:
      • Initiate an investigation and oversight review into alleged non-consensual human experimentation and Electroconvulsive Shock Torture (ECST) conducted through the misuse of electrophysiological and neuromodulation technologies
      • Issue a Federal Register notice clarifying that the non-therapeutic use of electroconvulsive shock and electromagnetic neuromodulation devices outside approved research or clinical contexts constitutes a violation of human-subject protections under the Common Rule(45 CFR 46) and FDA device regulations (21 CFR Parts 50 and 56)
      • Review and revoke, where appropriate, device clearances or research exemptions that enable non-consensual human application of electrophysiological stimulation
    • The petition is then backed by the following claims:
      • Alleged ongoing use of electrophysiological stimulation and electromagnetic exposure causing pain, seizure-like events, and neurological harm amounting to Electroconvulsive Shock Torture (ECST)
        • The petitioner has journal records indicating this and is conssistent with electrophysiological stimulation under UN Convention Against Torture and the Istanbul Protocol (2022)
      • ECST is distinct from Electroconvulsive Therapy (ECT) which is a regulated medical treatment
      • Citing federal regulations mentioned above and that human experimentation cannot be performed without consent

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    Initial Ethical Analysis

    I immediately thought of four ethical frameworks once I read the petition.

    I'd like to walk through each of these frameworks and share my analysis as it relates to the case.

    Nuremberg Code

    How does this NOT violate every entry in the Nuremburg Code?

    Though there isn't a reason to walk through each statement one by one, I feel we should. Each statement has its own impact to the case:

    • "The voluntary consent of the human subject is absolutely essential. This means that the person involved should have legal capacity to give consent; should be situated as to be able to exercise free power of choice, without the intervention of any element of force, fraud, deceit, duress, over-reaching, or other ulterior form of constraint or coercion, and should have sufficient knowledge and comprehension of the elements of the subject matter involved as to enable him to make an understanding and enlightened decision. This latter element requires that before the acceptance of an affirmative decision by the experimental subject there should be made known to him the nature, duration, and purpose of the experiment; the method and means by which it is to be conducted; all inconveniences and hazards reasonably to be expected; and the effects upon his health or person which may possibly come from his participation in the experiment.

      The duty and responsibility for ascertaining the quality of the consent rests upon each individual who initiates, directs or engages in the experiment. It is a personal duty and responsibility which may not be delegated to another with impunity."
      • This one is self explanatory as this is one of the claims against the alleged party
    • "The experiment should be such as to yield fruitful results for the good of society, unprocurable by other methods or means of study, and not random and unnecessary in nature."
      • You will see my rationale behind this as I explore the other documents within the investigation. I can assure you this was not based on "good science".
    • "The experiment should be so designed and based on the results of animal experimentation and a knowledge of the natural history of the disease or other problem under study that the anticipated results will justify the performance of the experiment."
      • This doesn't sound applicable based off the files within the docket.
    • "The experiment should be so conducted as to avoid all unnecessary physical and mental suffering and injury."
      • I believe the name of this petition explains enough as to why this statement is in direct violation.
    • "No experiment should be conducted where there is an a priori reason to believe that death or disabling injury will occur; except, perhaps, in those experiments where the experimental physicians also serve as subjects."
      • Again, the docket's title is plenty of explanation for this statement's violation.
    • "The degree of risk to be taken should never exceed that determined by the humanitarian importance of the problem to be solved by the experiment."
      • Self explanatory...
    • "Proper preparations should be made and adequate facilities provided to protect the experimental subject against even remote possibilities of injury disability or death."
      • This relates to the "good sciences" article.
    • "The experiment should be conducted only by scientifically qualified persons. The highest degree of skill and care should be required through all stages of the experiment of those who conduct or engage in the experiment."
      • A blend of being "self explanatory" and "good science".
    • "During the course of the experiment the human subject should be at liberty to bring the experiment to an end if he has reached the physical or mental state where continuation of the experiment seems to him to be impossible."
      • Given that consent was acquired, it's safe to assume that the participant wasn't given any liberties.
    • "During the course of the experiment the scientist in charge must be prepared to terminate the experiment at any stage, if he has probable cause to believe, in the exercise of the good faith, superior skill and careful judgement required by him that a continuation of the experiment is likely to result in injury, disability, or death to the experimental subject."
      • Again, a blend of being "self explanatory" and "good science".

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    Belmont Report

    This can be reviewed here: Belmont Report.

    I immediately saw that this was in direct violation of two out of the three tenets:

    • Respect for Persons
      • Violating informed consent is in direct violation of this principle.
      • Specifically, violating the fact that folks are autonomous agents and that consent must be voluntarily given to be valid.
    • Beneficence
      • Though it is unclear what any benefits would be from this study, potential harms were not minimized.
      • This also ties into violation of the Hippocratic Oath, which is foundational to medical ethics.

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    ICH GCP E6(R3)

    This can be reviewed here: ICH GCP E6(R3).

    Of course, this is under the assumption that this was a clinical trial:

    • "Clinical trials should be conducted in accordance with the ethical principles that have their origin in the Declaration of Helsinki and that are consistent with GCP and applicable regulatory requirement(s). Clinical trials should be designed and conducted in ways that ensure the rights, safety and well-being of participants."
      • I won't dive further into this since I already mentioned the Declaration of Helsinki.
    • "Informed consent is an integral feature of the ethical conduct of a trial. Clinical trial participation should be voluntary and based on a consent process that ensures participants (or their legally acceptable representatives, where applicable) are well-informed."
      • Again, one of the most compelling elements of this case.
    • "Clinical trials should be subject to an independent review by an IRB/IEC."
      • This ties into the "good science" article.
    • For principles 4-11:
      • See bullet point above.

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    Declaration of Helsinki

    This can be reviewed here: Declaration of Helsinki.

    Not that I want to take shortcuts here, but in case you didn't know there are 30+ tenets! It's safe to say that there is a lot of overlap with these ethical principles. For the sake of not being repetitive, we can assume this case violated the Helsinki tenets. I can only imagine if we walked through each principle how long this post would be!

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    Review of Remaining Documentation within the FDA Docket

    I'm curious of how spot on my analysis is now that we are going to review other critical documents.

    Let's deep dive into the other elements of the case.

    The "Good Science" Article

    Here is the article: Bad Science Used to Support Torture and Human Experimentation.

    In short, this relates to FDA-2025-P-5514-0004: Exhibit E-9 โ€” Misuse of Science in Torture Justifications. Upon review:

    • Exhibit E-9 discusses why Bad Science Used to Support Torture and Human Experimentation article is not "good science".
    • The "good science" articles details how the Office of Medical Services (OMS) and affiliated behavioral scientists falsely claimed scientific validation by referencing internal field reports and memoranda as though they were controlled studies.
      • The science used to justify torture was bad because it repeatedly failed to assess important long-term physical and mental health outcomes.
      • To avoid this from happening again, recommendations with respect to the following topics were provided:
        • Independence and accountability
        • Peer review and monitoring
        • Training and education
        • Government accountability
    • Further, per Exhibit E-9:
      • This misuse of empirical language gave policy-makers a pseudo-scientific justification to continue torture while claiming medical supervision.
      • The OMSโ€™s interpretation of physiological data ignored established neurobiological evidence showing that severe stress, hypoxia, and sleep deprivation cause long-term neurocognitive and psychological injury.
      • By reclassifying human suffering as โ€œdata,โ€ medical personnel violated:
        • The Nuremberg Code (1947),
        • The Declaration of Helsinki, and
        • The U.S. Common Rule (45 CFR 46)
      • The authors emphasize that no circumstanceโ€”national security, emergency, or warโ€”permits deviation from these ethical standards.

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    Here, I reviewed the following documents:

    The first document complements FDA-2025-P-5514-0001 within the docket (associated with the original petition). Nature of violations described in greater detail (see image below):

    Initial legal and ethical frameworks were also introduced (see image below):

    For the second document:

    • This describes the complete legal framework for the case (i.e., regulations that are relevant to the docket).
    • Details can be reviewed within the file, to summarize:
      • The alleged experiments and interventions(electroconvulsive shock, electromagnetic fields, human-to-human neural interfacing) clearly fall under โ€œresearch involving devices or procedures not clinically approved.โ€
      • Due to no informed consent, IRB review, device labeling, or IDE authorization, actions described here directly violate 45 CFR 46 and 21 CFR 812.
      • These violations are compounded when the procedures are used as instruments of torture (i.e., they violate both human-rights and regulatory law).

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    The Coup De Gras

    This reviews FDA-2025-P-5514-0007: Torture Journal Entry by Kimberly C. Tanner 10-17-25.

    In essence, this incredibly vivid journal entry describes the torture Kimberly C. Tanner went through during these experiments. I'd like to use these next couple of bullet points solely to highlight direct quotes from the journal entry. In my opinion, these horrific statements speak to the importance of this FDA investigation and the magnitude of the situation.

    • "Fearmongering is a factor, but real fear is at play since I have no idea how many years this will take off my life, how much damage is being done to my brain and the rest of my body including other organs of my body since no part of my body is off limits to Operator #1, who also has no conscience and behaves maliciously most of the time."
    • "Iโ€™d like to also add that non-consensual human-human interfacing is molestation in and of itself."

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    Closing Thoughts

    This song played in my head as soon as I formatted this section:

    "Closing time, you don't have to go home but you can't stay here"

    handwritten message on brown background

    I'm thinking this must have been a FDA-regulated study (given the device regulations that were cited. However, I also wonder if this was DOD-sponsored research. One of the ethical/legal frameworks that was mentioned within the case was specific to DOD. I wonder if it is safe to assume that this isn't a clinical trial (given ICH GCP E6(R3) guidelines weren't mentioned). I know that I'm not a lawyer. However, I did have fun analyzing this case. It's amazing that these ethical principles that were applied to human rights violations in the 1940s still hold true today.

    Just as the image says, human rights are not optional. Participant protections are not optional. This is why myself (and other professionals within our field) hold these ethical tenets so close to heart.

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    I hope you found this post thought-provoking and insightful!