All research projects conducted by, participated in, or involving Dixie State University Faculty, Staff, and students involving human subjects requires review and approval by the DSU Institutional Review Board.
An IRB is an ethics committee composed of scientists and non-scientists who protect the rights of human subjects involved in research. The IRB is charged with the responsibility of reviewing and overseeing this research conducted under the aegis of Dixie State University.
In light of the IRB's mission to protect human subjects, and the potential regulatory consequences of not obtaining IRB review and approval for human subjects research, you should choose to err on the side of caution and consult the IRB when you are uncertain whether your study is human subjects research or not.
Terms & Definitions
The first question to consider with respect to IRB review is whether the research project fits the definition of “research” with “human subjects,” as those terms are defined in the federal regulations that govern human subjects research.
"Research"
A systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalizable knowledge.
Activities which meet this definition constitute research for purposes of the federal regulations that protect human research subjects, whether or not they are conducted or supported under a program which is considered research for other purposes. Some demonstration and service programs may include research activities.
"Human Subject"
A living individual about whom an investigator (whether professional or student) conducting research obtains data through intervention or interaction with the individual, or identifiable private information."
"Living Individual"
Living individual – Cadavers, autopsy specimens, or specimens/ information from subjects who are now deceased are not "human subjects." Note, however, that the health information of deceased individuals is protected under federal and some state regulations.
If you plan to analyze health information of deceased individuals for your project, you should determine whether the health information associated with the data is "protected health information" (PHI) under the HIPAA Privacy Rule.
"About Whom"
To be considered research with "human subjects," the data received from a living individual must be about the person.
For example, if you are asking people for information on institutional policies, practices, and characteristics without obtaining data about the characteristics/opinions of the individuals providing the information, that does not involve research with human subjects (e.g., a survey asking institutional human resources offices about the number of individuals who work at an institution and what types of employee benefits are offered by the institution).
"Intervention"
Physical procedures by which data are gathered (for example, venipuncture) and manipulations of the subject or the subject's environment that are performed for research purposes.
"Interaction"
Communication or interpersonal contact between investigator and subject.
"Private Information"
Information about behaviour that occurs in a context in which an individual can reasonably expect that no observation or recording is taking place, and information which has been provided for specific purposes by an individual and which the individual can reasonably expect will not be made public (for example, a medical record).
Private information must be individually identifiable (i.e., the identity of the subject is or may readily be ascertained by the investigator or associated with the information) in order for obtaining the information to constitute research involving human subjects.
"Secondary Analysis" of data/specimens
If you will be obtaining identifiable private information or identifiable specimens that were collected in a prior research study so that you can conduct secondary analysis of the data/specimens, your study will be considered human subjects research.
In general, the HHS Office for Human Research Protections considers private information/specimens to be individually identifiable when they can be linked to specific individuals by the researcher either directly or indirectly through coding systems.
"Coded"
“Coded” means that:
- identifying information (such as name or social security number) that would enable the investigator to readily ascertain the identity of the individual to whom the private information or specimens pertain has been replaced with a number, letter, symbol, or combination thereof (i.e., the code); and
- a key to decipher the code exists, enabling linkage of the identifying information to the private information or specimens.
The HHS Office for Human Research Protections does not consider research involving only coded private information or specimens to involve human subjects if the following conditions are both met:
- the private information or specimens were not collected specifically for the currently proposed research project through an interaction or intervention with living individuals; and
- the investigator(s) cannot readily ascertain the identity of the individual(s) to whom the coded private information or specimens pertain.
Investigator inability to identify individual(s) may be due to the following examples:
- the investigators and the holder of the key enter into an agreement prohibiting the release of the key to the investigators under any circumstances, until the individuals are deceased (note that the HHS regulations do not require the IRB to review and approve this agreement);
- there are IRB-approved written policies and operating procedures for a repository or data management center that prohibit the release of the key to the investigators under any circumstances, until the individuals are deceased; or
- there are other legal requirements prohibiting the release of the key to the investigators, until the individuals are deceased.
"Multi-Institutional Research"
Multi-Institutional Research: In situations where multiple institutions are involved in carrying out a non-exempt research project, a question each institution has to consider is whether that institution's activities rise to the level of being "engaged" -- if engaged, IRB review is required of that institution's activities; if not engaged, IRB review is not required of that institution's activities.
The HHS Office for Human Research Protections has issued a Guidance on Engagement of Institutions in Human Subjects Research which discusses when institutions are considered to be engaged or not engaged in research.
In general, an institution is considered engaged in a particular non-exempt human subjects research project when its employees or agents for the purposes of the research project obtain:
- data about the subjects of the research through intervention or interaction with them;
- identifiable private information about the subjects of the research; or
- the informed consent of human subjects for the research
At least one institution must be determined to be engaged in any non-exempt human subjects research project that is funded by the U.S. Department of Health and Human Services. The OHRP Guidance sets out examples of situations where institutions would be considered engaged and not engaged in research.
Research Study Examples
If you are unsure whether or not a proposed quality improvement project should be classified as research, contact the IRB for guidance. If the data is re-examined or re-analyzed and new information surfaces that would contribute to generalizable knowledge, an application must be submitted to the IRB.
Without Human Subjects:
- Data collection for internal departmental or other University administrative purposes. Examples: teaching evaluations, customer service surveys.
- Information-gathering interviews where questions focus on things, products, or policies rather than people or their thoughts regarding themselves. Example: a survey of employers that asks whether the employers offer certain employee benefits programs, without asking for the opinions or thoughts of the individuals who respond to the survey.
- Class projects, research practica, and undergraduate thesis projects involving research methodology and course-assigned data collection. These activities generally do not constitute research because their purpose is to provide training in research as part of the overall educational mission of a program and are not designed to contribute to generalizable knowledge. However, if, for example, a student is involved in an activity designed to teach research methodologies and the instructor or student wishes to conduct further investigation and analyses in order to contribute to scholarly knowledge, the design of the project has changed such that it meets the above definition of research and requires IRB review, and the IRB must at that time review the research. Course instructors are responsible for assessing whether these activities meet the definition of research and are encouraged to contact the IRB for assistance if needed.
- Program evaluation/Quality improvement/Quality assurance projects are generally not considered research if these activities are designed specifically to assess or improve performance within a department, hospital or classroom setting. The intention of the project is not to generate conclusions that can be applied universally, outside of the immediate environment where the project will occur.
With Human Subjects:
- Studies that utilize test subjects for new devices, products, drugs, or materials.
- Studies that collect data through intervention or interaction with individuals, if the information is about the individuals (including their opinions/views/thoughts). Examples of this type of research include drug trials, internet surveys about alcohol consumption, studies that involve deception, research involving risky behaviours or attitudes, and open-ended interviews with minors that contribute to generalizable knowledge.
- Studies using private information that can be readily identified with individuals, even if the information was not collected specifically for the study in question.
- Studies that use bodily materials such as cells, blood, urine, tissues, organs, hair, or nail clippings, even if one did not collect these materials for the study. However, such research may be considered exempt or not human subjects research if the materials/data are coded and the investigator does not have access to the coding systems. For more information, read the guidance on research involving coded private information or biological specimens, provided by HHS.
- Studies that produce generalizable knowledge about categories or classes of subjects from individually identifiable information.
- Studies that use human beings to evaluate environmental alterations, for example, weatherization options or habitat modifications to their living or working space or test chamber.
Oral History Projects
and other ethnographic/qualitative interviews
It can be especially challenging to determine whether projects that involve oral history/ethnographic/qualitative interviews are human subjects research. As with all studies, the question involves looking at the research design and procedures using the definitions of "research" and "human subjects" set out in the federal regulations.
Generally speaking, if a project is limited to interviews that only document a specific historical event or the experiences of individuals without the intent to generalize findings or inform policy, the project would not be considered human subjects research. If the project is intended to produce generalizable conclusions (i.e., data collection intended to test economic, sociological, or anthropological models/theories) or inform policy, the project is considered human subjects research and should undergo IRB review.
Oral historians and qualitative researchers may want to create archives for the purpose of providing a resource for others to do research. Since the intent of the archive is to create a repository of information for other investigators to conduct research as defined by 45 CFR part 46, the creation of such an archive would constitute research that needs to undergo IRB review.
Because this is a particularly challenging area in which to determine whether IRB review is needed, we strongly recommend that you contact the IRB if you are unsure whether a project that will involve oral history/ethnographic/qualitative interviews should undergo IRB review.