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Governance of Biomedical Research in Singapore and the Challenge of Conflicts of Interest



This article discusses the establishment of a governance framework for biomedical research in Singapore. It focuses on the work of the Bioethics Advisory Committee (BAC), which has been instrumental in institutionalizing a governance framework, through the provision of recommendations to the government, and through the coordination of efforts among government agencies. However, developing capabilities in biomedical sciences presents challenges that are qualitatively different from those of past technologies. The state has a greater role to play in balancing conflicting and potentially irreconcilable economic, social, and political goals. This article analyzes the various ways by which the BAC has facilitated this.



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1. Han, FK, Zuraidah, I, Chua, MH, Lim, L, Low, I, Lin, R, et al. Lee Kuan Yew: Hard Truths to Keep Singapore Going. Singapore: Straits Times Press; 2011, at 25.

2. Fukuyama, F. The Origins of Political Order: From Prehuman Times to the French Revolution. New York: Farrar, Straus and Giroux; 2011, at 470.

3. See note 2, Fukuyama 2011, at 253, 256–7.

4. Ong, A. An analytics of biotechnology and ethics at multiple scales. In: Ong, A, Chen, N, eds. Asian Biotech: Ethics and Communities of Fate. Durham, MD, and London: Duke University Press; 2010:151, at 15–16.

5. In the area of human embryonic stem cell research, Catherine Waldby illustrates how the BAC has utilized a moderate majority opinion to develop a liberal but well-regulated regime and is suited to facilitate international collaboration and compliance with future therapeutic requirements. Waldby, C. Singapore biopolis: Bare life in the city-state. East Asian Science, Technology and Society: An International Journal 2009;3:367–83.

6. Wong, J. Betting on Biotech: Innovation and the Limits of Asia’s Developmental State. Ithaca, NY, and London: Cornell University Press; 2011, at 7.

7. See note 6, Wong 2011, at 15.

8. Funnell, W, Jupe, R, Andrew, J. In Government We Trust: Market Failure and the Delusions of Privatisation. London: Pluto Press; 2009, at 17. Neoliberal thinking was traced to the 1970s, when liberal democracies abruptly turned away from what was perceived to be the unchecked growth of the welfare state to public sector reform that forced the retreat of government from the provision of social services. This phenomenon may be further attributed to the inability of Keynesian economics to deal with the “stagflation” of the 1970s (see Funnell et al. 2009, at 12–16).

9. Giddens, A. The Third Way and Its Critics. Cambridge: Polity Press; 2000, at 51.

10. See note 8, Funnell et al. 2009, at 273–4. They correctly observe that concern over the ability of public servants to influence resource allocation decisions in ways that are detrimental to public interests is not necessarily addressed by reassigning such decisions to the market, for instance.

11. Ong, A. Neoliberalism as Exception: Mutations in Citizenship and Sovereignty. Durham, NC: Duke University Press; 2006, at 6.

12. Kohli, A. State-Directed Development: Political Power and Industrialization in the Global Periphery. New York: Cambridge University Press; 2004, at 385–6.

13. See note 6, Wong 2011, at 148–50.

14. Link, AN, Link, JR. Government as Entrepreneur. New York: Oxford University Press; 2009, at 158–60.

15. The mediatory function of the BAC is perhaps best illustrated in its recommendations for research involving embryonic stem cells. When interviewed, many of the BAC members considered this to be the BAC’s principal role. For a more detailed discussion of the functions, responsibilities, and work of the BAC, see Ho, C, Lim, S. The coming of bioethics to Singapore. In: Elliott, JM, Ho, C, Lim, S, eds. Bioethics in Singapore: The Ethical Microcosm. Singapore: World Scientific; 2010:129.

16. Drawing from her interviews with international scientists in Singapore, Gail Davies indicated that they enjoyed protection from the political protest that has accompanied research on biotechnology in Europe and stem cell research in the United States, and animal experimentation in both. Davies, G. Playing dice with mice: Building experimental futures in Singapore. New Genetics and Society 2011;30(4):433–41.

17. For a fuller analysis of this case, see Campbell, AV, Chin, J, Voo, TC. The clinician-researcher: A servant of two masters? In: Elliott, JM, Ho, C, Lim, S, eds. Bioethics in Singapore: The Ethical Microcosm. Singapore: World Scientific; 2010:89108.

18. Bioethics Advisory Committee. Research Involving Human Subjects: Guidelines for IRBs. Singapore: Bioethics Advisory Committee; 2004 Nov, at 55 (section 8).

19. Ho, C. Safeguarding the integrity of scientific research. Singapore Academy of Law Journal 2010;22:9941022.

20. Kleinert, S. Singapore statement: A global agreement on responsible research conduct. The Lancet 2010;376:1125–7. The Singapore Statement has no legal or regulatory effect and hence is not within the direct regulatory purview of government agencies.

21. Ministry of Health. Operational Guidelines for Institutional Review Boards. Singapore: Ministry of Health (Biomedical Research Regulation Division); 2007 Dec, at 8–9, para. 7.10.5, 7.12, section 10.

22. For a discussion of this sudden shift in policy in late 2010 and its effect on the scientific community, see Gelfert, A. Before biopolis: Representations of the biotechnology discourse in Singapore. East Asian Science, Technology and Society: An International Journal 2013;7:103–23.

23. Goldacre, B.Bad Pharma: How Drug Companies Misled Doctors and Harm Patients. London: Fourth Estate; 2012.

24. See note 18, Bioethics Advisory Committee 2004, para. 4.17, 5.58. Illustrations of such conflicts are set out by the BAC in its report. For a discussion of the COI provisions, see Ho, C. Conflicts of interest in biomedical research. Asia-Pacific Biotech News 2012;16(4):34–6.

25. See note 18, Bioethics Advisory Committee 2004, para. 5.36–5.41.

26. See note 18, Bioethics Advisory Committee 2004, para. 6.14–6.15. This requirement similarly applies to IRB members.

27. Dana, J, Loewenstein, G. A social science perspective on gifts to physicians from industry. JAMA 2003;290(2):252–5.

28. Wazana, A. Physicians and the pharmaceutical industry: Is a gift ever just a gift? JAMA 2000;283(3):373–80.

29. Cain, DM, Loewenstein, G, Moore, DA. The dirt on coming clean: Possible effects of disclosing conflicts of interest. Journal of Legal Studies 2005;34(1):124.

30. See note 17, Campbell et al. 2010, at 107–8.

31. Brennan, TA, Rothman, DJ, Blank, L, Blumenthal, D, Chimonas, SC, Cohen, JJ, et al. Health industry practices that create conflicts of interest: A policy proposal for academic medical centers. JAMA 2006;295(4):429–33.

32. Campbell, AV. Bioethics: The Basics. London and New York: Routledge; 2013, at 131–4.

33. The CBmE was established in 2006 at the Yong Loo Lin School of Medicine of NUS. It publishes the quarterly online journal Asian Bioethics Review and undertakes a wide range of bioethics research, much of it in collaboration with overseas institutions.

The authors are grateful to Dr. Jacqueline Chin and Mr. Voo Teck Chuan for their comments and assistance with references.


Governance of Biomedical Research in Singapore and the Challenge of Conflicts of Interest



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