Here at UTC as our research activity has increased dramatically over the past several years, we are finding it necessary to pay greater attention to the policies and procedures followed by our IRB. Dr. Helen Eigenberg, Head of the Department of Criminal Justice, serves as Chair of the IRB. Helen convenes committee meetings and, where appropriate, conducts expedited reviews of certain research proposals that qualify.
It is the responsibility of each faculty member engaged in research involving human subjects to obtain IRB approval before beginning the research. This is a critical point, as federal regulations do not permit retroactive approval. The sanctions for conducting research with human subjects without prior approval can be quite severe, including prohibition of publishing or using the data in any way. Sanctions for student research without prior approval can include withdrawal of approval of the student's work product (which may in some cases mean denial of a degree for which the research product served as a contribution, such as a master's thesis or senior paper).
I cannot stress strongly enough that there is no human subjects research that is exempt from the requirement of IRB approval. Some research that involves human subjects in the form of anonymous surveys may qualify for either "exempt" status or for an "expedited review," which means it does not have to go before the full IRB for detailed analysis and review. But even in those situations, the appropriate forms must be filed and the research must be reviewed by the IRB Chair and/or other committee members. No individual faculty member can declare his or her research involving human subjects exempt from IRB review. "Exempt" means that it is exempt from review by the full IRB, but not exempt from submission and approval.
Many of us have routinely assumed that when we engage in research in which the human subjects remain unidentified or in which we protect the confidentiality of their identities, there is no potential harm, and therefore no requirement for IRB review. This is an erroneous assumption. Any research conducted by you or by your students that involves human subjects in any way (whether or not it is receiving funding from any source) must first be submitted to the IRB for review.
If you have any questions at all about whether your research, or that of your students, requires IRB approval, please direct them to Dr. Deborah Arfken, the IRB Administrator, or Dr. Helen Eigenberg, Chair of the IRB. If you have any doubts about whether your research involves human subjects, it is wise to err on the side of safety and contact Dr. Arfken or Dr. Eigenberg for clarification. The old saying that an ounce of prevention is better than a pound of cure surely applies here.
At a time when UTC is making huge strides in research activities, we want to be sure that we support and promote the efforts of our faculty and students. The IRB is here to assist you, not to place roadblocks in your way. It is also here to protect human subjects and to promote the interests of the University. Please take advantage of this important resource.
John Friedl, Ph.D., J.D.
Provost and Vice Chancellor for Academic Affairs
September 24, 2003