How do national guidelines frame clinical ethics practice? A comparative analysis of guidelines from the US, the UK, Canada and France.

International policies regulating clinical ethics committees' (CEC) roles are non-existent. Nonetheless, CECs have established themselves in several countries and there exist striking differences in the way these work. This international practice variation stems from the ways CECs developed, within particular legal, political, social and professional contexts. National guidelines and normative documents have been published in many countries regarding CECs. To better understand CECs' evolution and differences in various countries, we reviewed guidelines, position statements and normative papers which describe and frame the development of CECs in the United States, the United Kingdom, Canada and France. Systematic content analysis addressed guideline development, CECs' roles, consultation methods and CEC members' education requirements. Differing contexts informed the ways in which guidelines were developed. American CECs, established within a strongly litigious context are perceived to play strong decision-making roles, whereas British CECs, encouraged by clinicians, endorse a more supportive model. Canadian guidelines focus on the role of the ethicist, while the French model is interested in a theoretical interdisciplinary approach. This analysis shows important challenges facing the implementation of accountable CECs in different contexts and can help inform future policy development.