Commentary: Is there a problem Consent in Escrow can solve?

I welcome the opportunity to comment on Consent in Escrow by Van der Loos and her colleagues.1 The authors are correct in their premise that the conduct of human subject research after a natural ormanmade disaster is ‘rife with. . . ethical, legal and policy challenges’.2 But I disagree with their conclusion that a revision to the process of informed consent used in the conduct of such research will overcome any of these challenges. The authors’ introduction points out two of what I believe to be two of the three key barriers to the conduct of post-disaster research. First, they mention the challenge of conducting research in a settingwhere the basic health and social services infrastructure has been damaged or destroyed.The ethical conduct of human subject research in the wake of Hurricane Katrina for example was likely hindered by the lack of local health care providers of institutions with whom investigators could collaborate or to whom they could refer subjects in need of additional health or mental health care. Second, the authors mention the challenges researchers face when conducting time sensitive research in need of rapid review by an Institutional Review Board (IRB). In general, domestic IRBs have limited experience with or mechanisms in place to provide a quick review of research. This challenge is likely exacerbated when the disaster has struck a low resource region that has nomechanism in place for review and oversight of human subject research. Third, and not mentioned by the authors, is the lack of responsive, flexible funding mechanisms to support the conduct of time sensitive research in the wake of a natural disaster. Once a funding application is submitted, the standard review and funding cycle for a Federal grant is six to eight months.3 An investigator interested and capable of conducting research immediately after a disaster must seek alternative