Thus, both policies suggest that the primary researcher may not bear sole responsibility for handling IFs and IRRs that emerge at the biobank and secondary research levels. Indeed, there are reasons to avoid placing all responsibilities on the primary researcher.85 The primary researcher may have limited knowledge and understanding of the biobank and secondary research and the meaning of the IFs/IRRs found there. Further, IFs or IRRs may be discovered by the biobank or secondary researchers years or decades after the original research has been completed. The primary researcher’s funding may be expired at that point. The primary researcher may actually be retired, departed from the institution, or deceased. Note that a recent consensus statement recommends that researcher obligations to manage IRRs end with the expiration of research funding, though the researcher may exercise his or her discretion to address IRRs beyond that point.86
