Researchers are responsible for obtaining appropriateapproval before
conducting research involving human subjects. The need for approval
rests on three seemingly obvious but not always easy-to-interpret considerations:
1) whether the work qualifies as research, 2) whether it involves human
subjects, and 3) whether it is exempt. All three considerations are
discussed in the Common Rule and guide decisionmaking about the use
of human subjects in research. The authority to make decisions about
the need for approval rests with the Institutional Review Board (IRB,
discussed below) or other appropriate institutional officials.
Research.
The Common Rule defines research as “systematic investigation,
including research development, testing and evaluation, designed to
develop or contribute to generalizable knowledge” (§ 46.102(d),
see box, next page, for full definition). This means that a project
or study is research if it:
- is conducted with the intention of drawing conclusions that have
some general applicability and
- uses a commonly accepted scientific method.
The random collection of information about individuals that has no
general applicability is not research. Scientific investigation that
leads to generalizable knowledge is.
Human
subjects. Human subjects are “living individual(s)
about whom an investigator conducting research obtains: (1) data through
intervention or interaction with the individual; or (2) identifiable
private information” (§ 46.102(f), see box, next page, for
full definition). Humans are considered subjects and covered by Federal
regulations if the researcher:
- interacts or intervenes directly with them, or
- collects identifiable private information.
If one of these two conditions applies and if the project or study
qualifies as research, then institutional approval is needed before
any work is undertaken.
Exempt
research. Some studies that involve humans may be exempt
from the requirements in the Federal regulations. Studies that fall
into the following categories could qualify for exemptions, including:
- research conducted in established or commonly accepted educational
settings;
- research involving the use of educational tests;
- research involving the collection or study of existing data, documents,
records, pathological specimens, or diagnostic specimens, if unidentifiable
or publicly available;
- research and demonstration projects which are conducted by or subject
to the approval of department or agency heads; or
- taste and food quality evaluation and consumer acceptance studies.
It is critically important to note, however, that decisions about whether
studies are exempt from the requirements of the Common Rule must be
made by an IRB or an appropriate institutional official and not by the
investigator.