|
Minimal risk
Expedited Review
To qualify for expedited review (see 45
CFR 46.110), an activity must:
Minimal risk: "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" (from 45
CFR 46.102(i)).
Examples of minimal risk research:
- non-invasive recording of data from subjects
- minimal blood draw amounts
- voice recordings
- non-stressful research on individual or group behavior
- moderate exercise by healthy volunteers
When making a decision about minimal risk of research,
consider both magnitude and likelihood of risk. A more
serious risk may be permissible if its probability is
extremely low. For example, airplane flight carries
a risk of death, but it occurs only once in some millions
of passenger miles.
Risks of ordinary, non-invasive diagnostic tests such
as routine blood draws in adults, general physical exams,
pen-and-paper tests, and ultrasound exams (at accepted
levels) are okay; however, minimal risk may be age-
or context-dependent: blood draws may be minimal risk
for someone old enough to give consent, but not for
a needle-shy child. And the context-dependent "ordinary"
risk of a sick patient experiencing numerous invasive
procedures differs from that of a healthy individual.
Remember that risks need not be "physical" to be "greater
than minimal." For example: a privacy/confidentiality
risk, informational risk, or risk of embarassment may
qualify the research as "greater than minimal risk,"
requiring full IRB review.
No risk
Screening for IRB Review Exemption
DHHS Guidelines (45 CFR Part 46.101(b) and (c)) define
research as exempt from further IRB review when the
research involves no risk to the subject. Research that
is considered exempt from full IRB review must still
be submitted to the IRB and screened for exempt status.
The final determination of level of review will be made
by the IRB upon receipt of the application form.
Examples of exempt research: survey interview research
with adult subjects; the use of nonidentifiable laboratory
specimens; review of nonidentified existing records;
observation of the public behavior of subjects where
there is no manipulation of the subject; and some educational
testing and classroom activity.
Use the Exempt Review Categories of Research to decide
which exemption category might apply to your research
and which form to then use. If you don't see a category
for your research, expedited or full IRB review is probably
required.
Exempt Review Categories of Research
Category 1. Research conducted in educational
settings, involving normal educational practices.
Federal
Definition
Examples of Research in Category 1:
- Evaluating the use of accepted or revised standardized
tests
- Testing or comparing a curriculum or lesson
- A program evaluation of pharmacy continuing education
Category 1 Form:
Investigational Strategies in Educational Setting
Category 2. Research involving the use of educational
tests (cognitive, diagnostic, aptitude, achievement),
survey procedures, interview procedures or observation
of public behavior.
Federal
Definition
Examples of Research in Category 2:
- Surveying teachers, nurses, or doctors about a
technique or an outcome
- Interviewing managers about a management style
or best practice
- Conducting a focus group about an experience or
an opinion of a community program
Category 2 Form:
Surveys/Interviews, Standard Educational Tests, Observation
of Public Behavior
Category 3. Research involving the activities
in category 2 and the human subjects are elected or appointed
public officials or candidates for public office.
Federal
Definition Examples of Research in Category
3:
- Interviewing public officials about a local or
global issue
Category 3 Form:
Public Officials, Surveys/Interviews, Educational
Tests, Observation of Public Behavior
Category 4. Research involving the collection
or study of existing data, documents, records, pathological
specimens, or diagnostic specimens.
Federal
Definition
Examples of Research in Category 4:
- Analyzing de-identified tissue samples or data
set
- Analyzing de-identified national test scores
- Analyzing census data about aging or housing
Category 4 Form:
Existing Data: Records Review, Pathological Specimens
Category 5. Reserved for Federal Government
Research. Not available for local IRB exemptions.
Federal
Definition
Category 6. Taste and food quality evaluation
and consumer acceptance studies.
Federal
Definition
Examples of Research in Category 6:
- Taste testing whole grain food products
- Comparing taste or smell of molasses, cheese or
milk
- Sampling texture of ice cream
Category 6 Form:
Food Quality and Consumer Acceptance Studies
What if more than one category applies to the research?
Complete the exempt application form where the majority
of the research clearly matches. Include description
of the additional exempt category research in this application
as well. |