I recently attended a seminar on IRBs (Institutional Review Boards) for Human Subjects Research. It was said that if students were doing any "research" in their courses involving human subjects from outside the course, this would likely need IRB approval. Sounds good, but I asked if this approval is needed even if the "research" is very informal, e.g., if students are presented with these sorts of assignment prompts: "Ask at least 3 people what they think about this topic," or "Ask at least three people what they think are common reasons to think p or not p (e.g., that doing X is wrong, that we have free will, that there is a God, etc." and so on: casual inquiry into what people think about philosophical issues.It was told that these potentially common learning activities might require IRB approval: it was pointed out that students might videotape their "research" and who knows what might come from that; perhaps people would somehow be harmed by being asked these sorts of questions.
I suspect that many philosophy instructors attempt to get students to
do these sorts of informal surveys and/and, at least, encourage them to
discuss class issues with people who are not in the class. My question, then, is whether anyone has encountered this issue and has done much to determine whether approval is indeed required for such activities, at least at their school. Thanks.
Part of the relevant Federal regulation is at
ReplyDeletehttp://www.hhs.gov/ohrp/humansubjects/guidance/45cfr46.html#46.101%28b%29
but it is subject to interpretation by individual institutions. Institutions are typically advised by attorneys who seek to prevent trouble for the institutions. "Costs" to faculty are often viewed as "external," so if the interpretation inhibits some desirable or benign behavior, that might be viewed by the institution as an acceptable consequence.
For one discussion among very many of whether IRBs have too much to say about faculty behavior, see, e.g. http://scatter.wordpress.com/2012/02/23/irbs-mission-creep-and-prior-restraint/
I asked my department head about this. He just laughed and said, "Philosophers don't do research." /facepalm
ReplyDeleteYou might try alerting your IRB office to the following unofficial guidance from the National Science Foundation: http://www.nsf.gov/bfa/dias/policy/hsfaqs.jsp
ReplyDeleteDoes research conducted as a classroom exercise count as human subjects research?
The Common Rule defines research as "a systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalizable knowledge" (§ 102.d)
This includes activities, which are intended to lead to published results, or for example, findings presented at a professional meeting. Classroom exercises, involving interactions with human participants, which are part of an educational program, and are not designed to advance generalizable knowledge, are not covered by this regulation. Similarly, evaluations for quality improvement or assessment of instruction are not considered research so long as they are not designed to create generalizable knowledge.