Manuel B. Garcia

Manuel B. Garcia serves as the Senior Director for Educational Technology and Digital Learning at FEU Institute of Technology, Manila, Philippines. Read More

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How Should You Respond to Ethics Committee Comments or Conditions?

A good response to ethics committee comments makes it easy to see what was requested, what you changed, where you changed it, and why. Learn how to prepare a clear point-by-point response and coordinated revision package.

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Responding to Ethics Committee Comments Guide 61 of 398
01 · The Question

How do you answer ethics comments without creating another round of confusion?

You receive the ethics committee's review and discover a mixture of questions, requested revisions, document corrections, conditions, and perhaps one or two comments you do not fully agree with.

The temptation is to revise the application quickly, upload the new files, and write something like "All comments have been addressed." That may feel efficient from the researcher's side. From the reviewer's side, it can mean reopening several documents and trying to discover what changed.

A strong response does the opposite. It creates a clear trail from each committee comment to your answer, the resulting revision, and the exact document or section where that revision appears.

02 · The Short Answer

Respond point by point and make every revision traceable

In Brief

Respond to ethics committee comments one by one, state clearly what you changed or why you are proposing a different response, identify where each revision appears, and submit coordinated versions of every affected study document.

Do not merely say that a comment has been addressed. Make the response easy to verify. Follow the committee's required resubmission format, version-control rules, and procedures for tracked changes, highlighted revisions, clean copies, or other documentation.

03 · What You Need to Know

Your response should function as a map of the revised study

Ethics committees need to determine whether their concerns have actually been resolved. That becomes much easier when the response package shows the relationship among the original comment, your answer, and the revised documents.

WHO's Research Ethics Review Committee provides a concrete example. Its submission guidance instructs investigators responding to review to address queries point by point in a cover memo and submit an amended protocol incorporating requested changes, with revisions marked through bolding, highlighting, or tracked changes. After approval, WHO requests a clean final protocol without those markings. These are WHO-specific procedures, but they illustrate a useful general principle: make changes visible during review and preserve a clean approved version afterward.

Start by classifying what each comment actually asks you to do

Not every committee comment requires the same response.

Type of comment What it usually needs from you Common mistake
Clarification Explain information that is unclear or incomplete Changing the study when explanation alone would have resolved the question
Required modification Revise the affected procedure or document as requested, or use the permitted process to justify an alternative Answering the comment without changing the document
Additional information Supply the missing methodological, ethical, administrative, or supporting information Repeating the original wording
Document correction Correct the affected material and check related documents for the same issue Fixing one file while leaving contradictions elsewhere
Condition of approval Satisfy and document the specified condition according to the committee's procedure Assuming the study may begin before the condition is verified

This first step prevents overreaction. A reviewer asking "Please clarify how recordings will be stored" has not necessarily instructed you to change the storage system.

Use a point-by-point response

Preserve the committee's numbering or order whenever practical. Reproduce or accurately identify each comment, then place your response immediately beneath it.

A useful response tells the reviewer four things:

What was requested Identify the committee's comment or condition clearly.
What you did State whether you revised, clarified, supplied information, or proposed an alternative.
Where it changed Identify the protocol section, application field, consent form, instrument, recruitment material, or other affected document.
Why, when necessary Explain the reasoning when the response is not self-evident or when you are proposing something different from the requested solution.

The objective is verification. A reviewer should not need detective skills to discover whether a requested change appears somewhere in a 40-page protocol.

Do not answer "Done" when the reviewer needs evidence

Consider the comment: "Please clarify what happens to audio recordings after transcription."

A response saying "Done" confirms almost nothing. A stronger response might explain that the protocol and participant information have been revised to state that recordings will be stored in the approved location, accessed only by specified personnel, and deleted at the approved stage after transcription and verification.

The exact procedure depends on the study. What matters is that the response communicates the substantive resolution and directs reviewers to the revised material.

Revise every document affected by the same change

One committee comment can propagate through the submission package.

If interview duration changes from 60 to 45 minutes, check the protocol, application, participant information sheet, consent form, recruitment advertisement, and any scheduling materials that mention duration.

If compensation changes, search every participant-facing document. If a new risk is added, review both the risk section and the consent information. If recruitment changes, check whether eligibility and contact procedures elsewhere still make sense.

Watch Out

Do not fix a contradiction by creating another contradiction. Whenever a committee comment changes a fact about the study, search the complete submission package for every other place where that fact appears.

Use tracked or highlighted revisions when the committee requests them

Reviewers often need to distinguish new material from the version they already reviewed.

WHO's submission guidance, for example, asks for requested amendments to be incorporated into the protocol and marked through bolding, highlighting, or track changes during the response stage. It requests a clean final version after approval.

Your committee may require a different convention, such as a redlined copy plus a clean copy, highlighted PDFs, a change table, or only a revised document with version numbers. Follow its format rather than creating your own elaborate color system.

Do not make unrelated changes silently

While revising the protocol, you notice another paragraph that could be improved. Then you decide to adjust an eligibility criterion, replace two interview questions, change the survey platform, and rewrite the recruitment advertisement.

Now the committee is reviewing more than its original comments.

Necessary corrections and genuinely important updates should not be hidden, but distinguish them from committee-requested revisions. If you introduce additional changes, disclose them clearly and follow the committee's requirements for reviewing them.

This is particularly important because changes to approved research may require prior review under applicable systems. OHRP's current written-procedures guidance for U.S. IRBs emphasizes procedures for reporting proposed changes and ensuring that changes to approved research are not initiated without prior IRB review and approval except where necessary to eliminate apparent immediate hazards to participants.

If you disagree, answer the ethical concern rather than ignoring the requested change

You do not need to pretend to agree with every comment.

If a requested change would materially damage the methodology, is based on a factual misunderstanding, or can be addressed through a better safeguard, explain that reasoning and propose an alternative through the committee's review process.

The key distinction is between a reasoned response and silent refusal. If you disagree with a requested ethics change, make the disagreement explicit enough for the committee to evaluate it.

Do not bury the response beneath a literature review

Some comments need evidence. That does not mean every response requires three pages of citations.

If a committee questions whether removing an item invalidates a standardized instrument, cite the instrument documentation or validation evidence relevant to that point. If the concern involves data security, explain the technical control. If it involves a regulatory requirement, identify the applicable rule or authoritative guidance.

Evidence should resolve the issue, not demonstrate that you own reference-management software.

Be especially precise when the committee imposes a condition

A condition is not merely a suggestion for improving the manuscript.

OHRP guidance distinguishes circumstances in which an IRB may approve research with conditions from situations in which it must defer approval pending further review. In conditional approval, the IRB has already been able to make the required approval determinations on the assumption that specified conditions will be satisfied. The investigator's responsive material still needs to be reviewed in the manner specified by the IRB.

WHO's Research Ethics Review Committee similarly describes conditional approval as contingent on an adequate response to the satisfaction of the reviewers or Chair, with required amendments incorporated and resubmitted.

Because terminology varies, respond to the exact conditions in your decision letter rather than assuming that "conditional approval" has one universal operational meaning.

Check whether your response deadline matters

Some committees specify how long investigators have to respond before an application closes, expires, or requires further review.

OHRP guidance notes that institutional procedures may set deadlines for investigators to submit responsive materials after an IRB requests changes or clarifications. A prolonged delay can also mean that new information relevant to risk or approval determinations needs to be disclosed when the researcher eventually responds.

Check your own committee's timeline. Do not assume an ethics application waits indefinitely in suspended animation.

Conduct a final cross-document audit before resubmitting

After answering every comment, temporarily stop reading the response letter and inspect the revised study as a whole.

Check:

  • study title and identifiers;
  • participant numbers and eligibility;
  • recruitment procedures;
  • study procedures and duration;
  • risks and safeguards;
  • potential benefits;
  • compensation;
  • consent procedures;
  • data collection and retention;
  • contact information;
  • document dates and version numbers.

A response can address every comment individually and still leave the revised submission internally inconsistent.

04 · A Practical Example

Turn one ethics comment into a traceable revision

Hypothetical Example

A committee asks for clearer handling of participant distress

A researcher plans interviews about experiences of workplace bullying. The committee comments: "Please clarify how the researcher will respond if a participant becomes distressed during the interview and ensure that this information is reflected in participant-facing materials."

Weak response "Noted. The documents have been revised accordingly."
Direct answer The researcher explains that participants may pause, skip a question, or stop the interview without penalty and describes the study-specific procedure the interviewer will follow if distress occurs.
Protocol revision The distress-response procedure is added to the section describing interview procedures and risk management.
Participant-document revision The participant information is updated so participants know before consenting that sensitive discussion may cause discomfort and that they can decline questions or stop.
Response mapping The response identifies the exact documents and sections changed and submits them using the committee's required revision format.

The reviewer can now see both the substantive answer and the documentary evidence that the study has been revised consistently.

05 · What Researchers Often Get Wrong

Common mistakes when answering ethics comments

Misconception

"All comments addressed" is an adequate response letter

It forces reviewers to discover every revision themselves. A point-by-point response makes it possible to verify what changed and whether the concern has actually been resolved.

Misconception

I only need to revise the document the reviewer mentioned

A change may affect several documents even when the comment names only one. Review the entire submission for corresponding statements so that participants, reviewers, and researchers are working from the same study description.

Misconception

If I disagree, I should simply leave the original text unchanged

No. Explain the disagreement and the ethical or methodological reasoning behind your proposed alternative. Silence does not tell the committee whether you overlooked the comment or deliberately rejected it.

Misconception

I should make every improvement I can while the application is reopened

Unrelated substantive changes can expand the review and create new ethical questions. Make necessary updates, but identify additional changes clearly rather than slipping them into a response package unnoticed.

Misconception

Conditional approval means the remaining comments are optional

No. Conditional approval is contingent on satisfying specified conditions under the applicable procedure. The exact operational consequences depend on the committee's rules and decision letter.

06 · What This Means for You

Make the committee's second review easier than the first

A useful response package should let a reviewer move directly from comment to response to revised document without reconstructing the history of the application.

A simple decision framework

If the committee asks for clarification
Answer the question directly and revise the protocol as well if the clarification belongs in the permanent study description.
If the committee requires a change
State what you changed and identify every affected document and location.
If you disagree with the proposed change
Explain why and propose an alternative that addresses the underlying ethical concern.
If one revision changes a fact appearing elsewhere
Search the complete submission package and update all corresponding references.
If you introduce an additional change not requested by the committee
Disclose it explicitly and explain it rather than hiding it among requested revisions.
If the decision includes conditions
Respond to each condition and verify what further confirmation is required before treating the study as authorized to begin.

Once the response is submitted, do not infer approval from silence, successful upload, or the fact that the requested changes were straightforward. Wait for the committee's formal determination and then verify what that determination actually permits.

07 · A Quick Checklist

Check your response package before resubmission

Before responding to ethics committee comments, check:
Every committee comment or condition has a corresponding point-by-point response.
Each response states what was changed, clarified, supplied, or proposed instead.
The response identifies the revised document and location when a change was made.
All documents affected by the same substantive change have been updated consistently.
Tracked, highlighted, clean, or redlined copies follow the committee's required submission format.
Any disagreement is explained explicitly and supported with relevant reasoning or evidence.
Additional changes not requested by the committee are identified rather than silently inserted.
Document titles, dates, and version numbers clearly distinguish the revised files from earlier drafts.
You have checked the response deadline and understand what further committee confirmation is required before research may proceed.
08 · Frequently Asked Questions

Questions about responding to ethics committee feedback

Should I respond to every ethics committee comment separately?

Usually yes when the committee provides separate queries or conditions. WHO's Research Ethics Review Committee, for example, explicitly requests point-by-point responses. Follow your own committee's required format, but make it possible to verify how every issue was handled.

Do I need to change the protocol if I explained the issue in my response letter?

If the clarification describes how the study will actually be conducted, it often belongs in the protocol or another permanent study document as well. Otherwise, the response letter and approved protocol may describe different levels of information. Follow the committee's instructions.

Can I disagree with one comment while accepting the others?

Yes. Make that distinction explicit. Implement the changes you accept and explain separately why you are asking the committee to reconsider another request or accept an alternative.

Should I submit clean documents or tracked changes?

Use the format required by the committee. Some committees want tracked or highlighted revisions during review and clean final documents after approval. Others require both revised and clean copies simultaneously.

Can I make unrelated protocol changes while responding?

You may need to disclose new developments or necessary corrections, but do not hide substantive additional changes among requested revisions. Identify them explicitly and follow the committee's procedure for reviewing them.

What if I do not understand a reviewer comment?

Use the committee's permitted communication route to seek clarification rather than guessing. A short clarification can prevent an unnecessary redesign and another review cycle.

Does submitting my response mean the study is now approved?

No. Submission of responsive materials is not itself approval. The committee or designated reviewer still needs to act on the response according to the applicable procedure.

09 · The Bottom Line

Make every response easy to verify

The Bottom Line

Respond to ethics committee comments point by point, explain what you changed or why you propose a different solution, identify where each revision appears, and keep every affected study document consistent.

A good response is not merely persuasive; it is auditable. Reviewers should be able to trace each concern to its resolution without searching through the submission, and researchers should wait for the required formal determination before treating the revised study as authorized.

10 · Sources and Further Reading

Authoritative guidance on responding to ethics review

11 · Cite this Guide

How to Cite This Guide

This guide is intended to be read, shared, and used in research, teaching, and academic work. If you draw on its ideas, explanations, or other content, please acknowledge the source by citing the guide. Doing so gives appropriate credit and helps your readers locate the original resource.

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