I take the possibility of serious ethical violations...well, seriously. I'm not sure whether the global cost of IRBs outweighs the benefits. But I'm pretty sur

I take the possibility of serious ethical violations...well, seriously. I'm not sure whether the global cost of IRBs outweighs the benefits. But I'm pretty sure that the sort of regulatory changes OHRP proposed (mentioned in the linked NYT article), where studies like mine with minimal possible risk are exempted from IRB requirements, seem good and important. I also wonder whether it's possible to monitor even the scary studies with lots of potential risks - like the herpes vaccine trial you link to - with a little more common sense and a little bit less insistence on everything being signed in pen.