THE ARTICLE by Oldham et al1 effectively discusses several of the most important criticisms of the National Bioethics Advisory Commission (NBAC) report,2 namely, that the focus on mental disorders stigmatizes patients with mental illness and that the reliance on only 2 levels of risk in determining the degree of protections required may markedly impede psychiatric research. After having reviewed the NBAC report, I still fail to understand why the NBAC believes that a 3-tier level of risk category system such as that described by the New York Advisory Work Group3 is unworkable and unacceptable. In their report, the NBAC writes that they "did not find these concerns convincing" in reference to their proposed 2-tier level of risk. They believed that the
Charney DS. The National Bioethics Advisory Commission Report: The Response of the Psychiatric Research Community Is Critical to Restoring Public Trust. Arch Gen Psychiatry. 1999;56(8):699–700. doi:10.1001/archpsyc.56.8.699
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