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Not all projects that collect information from human subjects require IRB review.  Some examples of these projects are included below, although this should not be considered an exhaustive list.  In general, the unifying feature of these projects is that there is no attempt to generalize these findings to a larger group.  However, this aspect alone cannot be used as the sole justification for not seeking IRB review.  

  • Projects undertaken solely for assessment purposes do not require IRB review unless subjects can be identified from their responses, data from assessment activities will be published or presented outside their original context, or information collected is of a sensitive nature.  
  • Projects collecting data in a classroom setting to illustrate a particular phenomenon, practice, or theory for educational purposes do not require IRB review unless these data will be published or presented outside of the classroom environment.  “Classroom setting” is broadly defined to include homework, online assignments, and other educational activities, whether or not they occur in a physical classroom or during a regular class meeting.  This category does not automatically encompass student-conducted research projects using human subjects, even if done as part of course requirements.  These projects may require IRB review even if their data will not be published or presented elsewhere.  If each student in the class is doing the same project (e.g., administering the same survey), then the instructor may be able to submit one IRB proposal covering the entire class.  
  • Scholarly and journalistic activities involving the collection and use of information that focuses directly on the specific individuals about whom the information is collected (e.g., oral history, biography, historical scholarship) do not require IRB review. Ethical practices consistent with professional organizations such as the Oral History Association and Center for Journalism Ethics are still required, and investigators conducting these types of projects are encouraged to inform the IRB of their project as a matter of professional courtesy.  
  • Public health surveillance activities authorized by a public health authority for the purpose of identifying, monitoring, assessing, or investigating situations of public health importance (e.g., onsets of disease outbreaks) do not require IRB approval.

Regardless of whether or not a particular project requires IRB review, investigators are still encouraged to follow informed consent procedures with their subjects and to take appropriate measures to maintain the confidentiality of their data.

It should also be recognized that some projects may initially not require IRB review, but could evolve into projects requiring review.  For example, if investigators notice an interesting phenomenon in their assessment data and decide to publish or present these findings, then the investigators should request IRB review for the project involving the data to be published/presented.  This would fall under the category of “secondary research” previously mentioned.

 

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