Types of IRB Review

Studies that are Human Subjects research must be submitted in IBIS for IRB review (exempt, expedited, or full board review). Below are the types of IRB review.

Exempt Review

• There are several different categories of minimal risk research defined as being exempt from Federal Policy for the Protection of Human Research Subjects.  This does not mean that they are exempt from IRB review.
  
  
• The IRB does not "approve" an exempt study but instead makes a determination that the project meets at least one of the federal exempt categories criteria.
  
  
• No annual continuing review is required and no expiration date will be listed on your approval letter.
  
  
• Amendments are required only if the changes to the project would alter the exemption criteria. 

• 1. Research, conducted in established or commonly accepted educational settings that specifically involves normal educational practices

  Research, conducted in established or commonly accepted educational settings, that specifically involves normal educational practices that are not likely to adversely impact students' opportunity to learn required educational content or the assessment of educators who provide instruction.

  This includes most research on regular and special education instructional strategies, and research on the effectiveness of or the comparison among instructional techniques, curricula, or classroom management methods.

• 2. Research that only includes interactions involving educational tests, survey procedures, interview procedures, or observation of public behavior

  Research that only includes interactions involving educational tests (cognitive, diagnostic, aptitude, achievement), survey procedures, interview procedures, or observation of public behavior (including visual or auditory recording) if one of the following criteria is met:

  • 2(i) - The information obtained is recorded by the investigator in such a manner that the identity of the human subjects cannot readily be ascertained, directly or through identifiers linked to the subjects.

  • 2(ii) - Any disclosure of the human subjects' responses outside the research would not reasonably place the subjects at risk of criminal or civil liability or be damaging to the subjects' financial standing, employability, educational advancement, or reputation.

  • 2(iii)- LIMITED IRB REVIEW REQUIRED The information obtained is recorded by the investigator in such a manner that the identity of the human subjects can readily be ascertained, directly or through identifiers linked to the subjects, and an IRB conducts a limited IRB review to make the determination required by §46.111(a)(7).

   

  Research Involving Children
  Research involving children cannot be classified as exempt under this category if the research involves survey, interview procedures, or observations of public behavior when the investigator participates in the activities being observed.
  
  Research involving children can be classified as exempt under this category if the research involves only educational tests and / or observation of public behavior where the investigator does not participate in the activities being observed and meets the other conditions of the exempt category.

• 3 Research involving benign behavioral interventions in conjunction with the collection of information from an adult subject

  Research involving benign behavioral interventions in conjunction with the collection of information from an adult subject through verbal or written responses (including data entry) or audiovisual recording if the subject prospectively agrees to the intervention and information collection and the following criteria is met:

  • 3 (i)(a)- The information obtained is recorded by the investigator in such a manner that the identity of the human subjects cannot readily be ascertained, directly or through identifiers linked to the subjects.

  • 3 (i)(b) - Any disclosure of the human subjects' responses outside the research would not reasonably place the subjects at risk of criminal or civil liability or be damaging to the subjects' financial standing, employability, educational advancement, or reputation
    
    
  • 3 (i)(c) - LIMITED IRB REVIEW REQUIRED- The information obtained is recorded by the investigator in such a manner that the identity of the human subjects can readily be ascertained, directly or through identifiers linked to the subjects, and an IRB conducts a limited IRB review to make the determination required by §46.111(a)(7).

  Benign Behavioral Interventions
  For the purpose of this provision, benign behavioral interventions are brief in duration, harmless, painless, not physically invasive, not likely to have a significant adverse lasting impact on the subjects, and the investigator has no reason to think the subjects will find the interventions offensive or embarrassing.

  Provided all such criteria are met, examples of such benign behavioral interventions would include having the subjects play an online game, having them solve puzzles under various noise conditions, or having them decide how to allocate a nominal amount of received cash between themselves and someone else.

  Deception Regarding the Nature or Purposes of the Research
  If the research involves deceiving the subjects regarding the nature or purposes of the research, this exemption is not applicable unless the subject authorizes the deception through a prospective agreement to participate in research in circumstances in which the subject is informed that he or she will be unaware of or misled regarding the nature or purposes of the research.

  Research Involving Children
  Research involving children cannot be classified as exempt under this exemption category.

• 4. Secondary research uses of identifiable private information or identifiable biospecimens

  Secondary research uses of identifiable private information or identifiable biospecimens (for which consent is not required)

  At least one of the following must be true to qualify for this exemption:

  • 4 (i) - The identifiable private information/biospecimens are publicly available.
    
    
  • 4 (ii) - Information is recorded by the investigator in such a manner that:
    • The identity of the subjects cannot readily be ascertained directly or through identifiers linked to the subjects,
    • The investigator does not contact the subjects, and
    • the Investigator will not re-identify 
      
      
  • 4 (iii) - The research involves only information collection and analysis involving the investigator's use of identifiable health information when that use is regulated under HIPAA (45 CFR parts 160 and 164, subparts A and E), for the purposes of “health care operations” or “research” as those terms are defined at 45 CFR 164.501 or for “public health activities and purposes” as described under 45 CFR 164.512(b).
    
    
  • 4(iv) - The research is conducted by, or on behalf of, a Federal department or agency using government-generated or government-collected information obtained for nonresearch activities, if the research generates identifiable private information that is or will be maintained on information technology that is subject to and in compliance with section 208(b) of the E-Government Act of 2002, 44 U.S.C. 3501 note, if all of the identifiable private information collected, used, or generated as part of the activity will be maintained in systems of records subject to the Privacy Act of 1974, 5 U.S.C. 552a, and, if applicable, the information used in the research was collected subject to the Paperwork Reduction Act of 1995, 44 U.S.C. 3501 et seq.

• 5. Federal Demonstration Projects

  Research and demonstration projects that are conducted or supported by a Federal department or agency, or otherwise subject to the approval of department or agency heads (or the approval of the heads of bureaus or other subordinate agencies that have been delegated authority to conduct the research and demonstration projects), and that are designed to study, evaluate, improve, or otherwise examine public benefit or service programs, including procedures for obtaining benefits or services under those programs, possible changes in or alternatives to those programs or procedures, or possible changes in methods or levels of payment for benefits or services under those programs.

  Such projects include, but are not limited to, internal studies by Federal employees, and studies under contracts or consulting arrangements, cooperative agreements, or grants. Exempt projects also include waivers of otherwise mandatory requirements using authorities such as sections 1115 and 1115A of the Social Security Act, as amended.

  Each Federal department or agency conducting or supporting the research and demonstration projects must establish, on a publicly accessible Federal Web site or in such other manner as the department or agency head may determine, a list of the research and demonstration projects that the Federal department or agency conducts or supports under this provision. The research or demonstration project must be published on this list prior to commencing the research involving human subjects.

• 6. Taste and food quality evaluation & consumer acceptance studies

  Taste and food quality evaluation and consumer acceptance studies:

  • If wholesome foods without additives are consumed, or

  • If a food is consumed that contains a food ingredient at or below the level and for a use found to be safe, or agricultural chemical or environmental contaminant at or below the level found to be safe, by the Food and Drug Administration or approved by the Environmental Protection Agency or the Food Safety and Inspection Service of the U.S. Department of Agriculture.

• 7. Storage or maintenance for secondary research for which broad consent is required

  Storage or maintenance of identifiable private information or identifiable biospecimens for potential secondary research use if an IRB conducts a limited IRB review (See HRP-319 - WORKSHEET - Limited IRB Review and Broad Consent)

• 8. Secondary research for which broad consent is required

  Research involving the use of identifiable private information or identifiable biospecimens for secondary research use. (See HRP-319 - WORKSHEET - Limited IRB Review and Broad Consent)

Expedited Review

Studies that involve no more than minimal risk but which do not meet any of the above criteria for exempt status may be eligible for Expedited Review. 

To qualify for expedited review procedure the research:

• Must involve no more than minimal risk to subjects. Minimal risk means that the probability and magnitude of harm or discomfort anticipated in the research are not greater in and of themselves than those ordinarily encountered in daily life or during the performance of routine physical or psychological examinations or tests.
  
  
• Must involve only procedures listed in one or more of the expedited review categories.
  
  
• Cannot be used where identification of the subjects and/or their responses would reasonably place them at risk of criminal or civil liability or be damaging to the subjects’ financial standing, employability, insurability, reputation or be stigmatizing, unless reasonable and appropriate protections will be implemented so that risks related to invasion of privacy and breach of confidentiality are no greater than minimal.
  
  
• Cannot be be used for classified research.

• 1. Clinical studies of drugs and medical devices only when certain conditions are met.

  1. (a) Research on drugs for which an investigational new drug application (21 CFR Part 312) is not required. (Note: Research on marketed drugs that significantly increases the risks or decreases the acceptability of the risks associated with the use of the product is not eligible for expedited review.)
  2. Research on medical devices for which (i) an investigational device exemption application (21 CFR Part 812) is not required; or (ii) the medical device is cleared/approved for marketing and the medical device is being used in accordance with its cleared/approved labeling.

• 2. Collection of blood samples by finger stick, heel stick, ear stick, or venipuncture

  1.  from healthy, nonpregnant adults who weigh at least 110 pounds. For these subjects, the amounts drawn may not exceed 550 ml in an 8 week period and collection may not occur more frequently than 2 times per week; or
     
     
  2. from other adults and children*, considering the age, weight, and health of the subjects, the collection procedure, the amount of blood to be collected, and the frequency with which it will be collected. For these subjects, the amount drawn may not exceed the lesser of 50 ml or 3 ml per kg in an 8 week period and collection may not occur more frequently than 2 times per week.

  *Children are defined in the HHS regulations as "persons who have not attained the legal age for consent to treatments or procedures involved in the research, under the applicable law of the jurisdiction in which the research will be conducted.

• 3. Prospective collection of biological specimens for research purposes by noninvasive means

  Examples:

  (a) hair and nail clippings in a nondisfiguring manner;
  (b) deciduous teeth at time of exfoliation or if routine patient care indicates a need for extraction; (c) permanent teeth if routine patient care indicates a need for extraction;
  (d) excreta and external secretions (including sweat);
  (e) uncannulated saliva collected either in an unstimulated fashion or stimulated by chewing gumbase or wax or by applying a dilute citric solution to the tongue;
  (f) placenta removed at delivery;
  (g) amniotic fluid obtained at the time of rupture of the membrane prior to or during labor;
  (h) supra- and subgingival dental plaque and calculus, provided the collection procedure is not more invasive than routine prophylactic scaling of the teeth and the process is accomplished in accordance with accepted prophylactic techniques;
  (i) mucosal and skin cells collected by buccal scraping or swab, skin swab, or mouth washings;
  (j) sputum collected after saline mist nebulization.

• 4. Collection of data through noninvasive procedures (not involving general anesthesia or sedation) routinely employed in clinical practice, excluding procedures involving x-rays or microwaves.

  Where medical devices are employed, they must be cleared/approved for marketing. (Studies intended to evaluate the safety and effectiveness of the medical device are not generally eligible for expedited review, including studies of cleared medical devices for new indications.)
  

  Examples:
  (a) physical sensors that are applied either to the surface of the body or at a distance and do not involve input of significant amounts of energy into the subject or an invasion of the subject=s privacy;
  (b) weighing or testing sensory acuity;
  (c) magnetic resonance imaging;
  (d) electrocardiography, electroencephalography, thermography, detection of naturally occurring radioactivity, electroretinography, ultrasound, diagnostic infrared imaging, doppler blood flow, and echocardiography;
  (e) moderate exercise, muscular strength testing, body composition assessment, and flexibility testing where appropriate given the age, weight, and health of the individual.

• 5. Research involving materials that have been collected, or will be collected solely for nonresearch purposes

  Research involving materials (data, documents, records, or specimens) that have been collected, or will be collected solely for nonresearch purposes (such as medical treatment or diagnosis).

  (NOTE: Some research in this category may be exempt from the HHS regulations for the protection of human subjects. 45 CFR 46.101(b)(4). This listing refers only to research that is not exempt.)

• 6. Collection of data from voice, video, digital, or image recordings made for research purposes

  Collection of data from voice, video, digital, or image recordings made for research purposes.

• 7. Research on individual or group characteristics or behavior or research employing survey, interview, oral history, focus group, program evaluation, human factors evaluation, or quality assurance methodologies.

  Research on individual or group characteristics or behavior (including, but not limited to, research on perception, cognition, motivation, identity, language, communication, cultural beliefs or practices, and social behavior) or research employing survey, interview, oral history, focus group, program evaluation, human factors evaluation, or quality assurance methodologies.

  (NOTE: Some research in this category may be exempt from the HHS regulations for the protection of human subjects. 45 CFR 46.101(b)(2) and (b)(3). This listing refers only to research that is not exempt.)

• 8. Continuing review of research previously approved by the convened IRB

  1. where (i) the research is permanently closed to the enrollment of new subjects; (ii) all subjects have completed all research-related interventions; and (iii) the research remains active only for long-term follow-up of subjects; or
     
     
  2. where no subjects have been enrolled and no additional risks have been identified; or
     
     
  3. where the remaining research activities are limited to data analysis.

• 9. Continuing review of research, where categories 2-8 do not apply

  Continuing review of research, not conducted under an investigational new drug application or investigational device exemption where categories 2-8 do not apply but the IRB has determined and documented at a convened meeting that the research involves no greater than minimal risk and no additional risks have been identified.

Full Committee Review