— Edward S. Mocarski, microbiology and immunology professor emeritus at Stanford University and Robert W. Woodruff Professor of Microbiology & Immunology at Emory University

Policy wonks at Hoover Institution understand that our country has laws that enforce widely accepted moral standards as well as ethical standards that have long applied to research, defining research integrity. There is little question that an action may be legal but unethical or illegal but ethical. Ethical principles are used to criticize, guide and interpret laws. Thus, laws and ethics remain separated by an enormous gray zone. This ambiguity set the stage for policy proposals in the form of a pamphlet (Eyes Wide Open: Ethical Risks in Research Collaboration with China) and discussion (Eyes Wide Open: Ethical Risks In Research Collaboration With China) orchestrated by Hoover affiliates Glenn Tiffert and Jeff Stoff. As the title suggests, the pamphlet proposes ways to address potential risks of academic research at the international level, particularly involving Chinese institutions. This Hoover initiative asks research institutions and governments outside China everywhere to “revise existing concepts of research integrity to ensure consistency with democratic values and define a common standard or set of conditions for ethical reviews of research that considers legal and political context and ethical and human rights risks”. The proposal goes further and suggests that “Federal agencies should deny or remove funding for research projects that involve collaboration with entities, based in authoritarian nations, that support mass surveillance and human rights abuses.” The recommendations include placing suspected foreign entities that have collaborated with US scientists on “the Entity List for export controls,” preventing scientific collaboration that has been deemed “contrary to U.S. national security and/or foreign policy interests”.

While weapons and intelligence research are clearly accompanied by national security risks, the Hoover initiative seeks an extremely broad application. Were it not for this proposal coming on the coattails of some pretty mean spirited, anti-China rhetoric and growing levels of legal proceedings involving US-based academic researchers who have little connection to weapons or intelligence research, the situation might be worth a hearty debate. The fact of the matter is that the FBI has already investigated a large number of academic researchers as a result of US Justice Department concerns over espionage and trade secret theft by China. The FBI round-up included both Chinese scientists, whether or not they were US citizens, permanent residents or scientists, as well as non-Chinese scientists with research links to Chinese institutions and scientists. There is little question that these events cast a pall over further collaboration between US scientists with researchers in Chinese institutions, no matter the topic of research involved, that neutralized any semblance of healthy scientific discourse prior to 2020. 

In a fashion that at one swoop both shocks and astounds, this Hoover initiative plans to formalize a form of “Thought Police” first imaged as an authoritarian tool, but here proposed for a free society. While they seek a kind of insular benefit on the surface, the proposal reveals a general overstepping as well as a lack of understanding of “research integrity” as generally accepted. The authors have clearly not taken the time to comprehend current standards of research ethics, research compliance and research objectivity despite widely accessible summaries.

Examples given in the proposal are jarring in their own right. For example, the Hoover proposal makes the unfortunate comparison between ethical review of research that would involve scientists within authoritarian regimes and ethical review by an Institutional Review Board (IRB) as currently exists in most academic institutions including Stanford. An IRB, of course, is responsible for reviewing and approving studies that focus on human subjects, mostly with the goal of assuring protections to study participants. Such research compliance affects most direct research into human disease and disease intervention. Importantly, IRB guidelines are not currently even applicable to US State Department and US Department of Defense human subjects research (which conforms to a different policy – proscribed in DOD INSTRUCTION 3216.02). 

Nevertheless, the Hoover Institution authors together with additional discussants uniformly stand in support of creating “civil society institutions” or “coalitions” that would “work together to develop knowledge and promote robust due diligence and information sharing on suspect entities based in authoritarian nations in order to uphold ethical standards and protect human rights”.

As any experienced academic scientist would attest, science pursuits and research proposals already involve a defined scope of work as well as extensive peer review. The future of science relies on imagination and so what scientists think drives progress and discovery. For my entire research career of over 40 years, scientific progress has depended on international collaboration and peer review that has not been readily identifiable with a single institution, nation or sponsoring agency, and certainly not restricted to a particular form of government. It must be acknowledged that China’s rapid rise in the scientific world comes in direct proportion to their growing investment. The way to counter their stratospheric rise is to match their investment. We should work to retain top research trainees in the US. We have not come close to keeping pace with Chinese spending on research and are now observing the consequences.

Nearly all scientific scholarship, whether it is conducted in a democratic nation or under an authoritarian regime, undergoes thorough peer review both before initiation and after execution. The scientific community knows no borders. Nation-based funding agencies may rely on their own scientists for peer review but international peer review has grown with the emergence of private nonprofit sponsors such as the Wellcome Foundation and the Bill and Melinda Gates Foundation as well as many others. International peer review across a worldwide community drives both objectivity and completeness. Peer review of published research results relies on an ever-more open, international peer review process with reviewers from wherever expertise in the topic exists in the world. Peer review is widely acclaimed for sustaining good science and applications of science that benefit humanity. Examples in the Hoover pamphlet and discussion focus on artificial intelligence (AI) research that facilitates surveillance by an authoritarian regime. Such examples do not apply to typical scientific collaborations. Besides, any algorithm supporting video surveillance of facial features overlooked by our huge federal intelligence infrastructure says more about the competency of the intelligence activities than anything about ethics. Where most international collaborations in science are pursued without military relevance, international collaboration that involves weapons and intelligence research clearly sits in a different place. Improvements in weapons and intelligence gathering have direct military application. Collaborations in such sensitive areas already undergo direct scrutiny by federal regulations and interventions. Although fairness, research integrity and human rights guarantees are all desirable ends, it is hard to see ”civil society institutions” adding any benefit.

Although so obvious to the concerned observer such as myself, the importance and focus of competent, extant intelligence activities was completely overlooked by the Hoover discussion group. Instead, discussants came across uniformly supporting the creation of new, novel national or even international initiatives aimed at regulating international research collaborations with the intent of stopping those that might yield benefits to “authoritarian regimes”, such as China. An overwhelming majority of research collaborations fall far from potential espionage, so in actuality this promises to become an agent of politics and nothing more. Although Hoover clearly navigates in its own waters and promotes policies with political nuance, it remains unclear whether the pamphlet co-authored by Drs. Tiffert and Stoff was even peer-reviewed by experts with broad knowledge of the topic. This policy initiative should die on the vine before a lot more innocent academic scientists have their careers ruined by conjecture and misdirected federal intrusion.