Jeremy Lopuch, Chair, College of Education, Sport, and Human Sciences
Valerie Jepson, College of Arts and Sciences
Sandra Neels, College of Visual and Performing Arts
Jane Thomas, College of Business and Technology
Jason Allen, Non-Affiliated Representative
Sebastian van Delden, Provost and Vice President for Academic Affairs, Authorized
University Representative, Ex-Officio Member
Kristin Smith, Director, Grants and Sponsored Research Development, Ex-Officio Member
Meeting Schedule and Submission Deadlines
Protocol due dates apply only to applications requiring Full Board review. Expedited
and Exempt reviews are conducted on an on-going basis.
Fall 2024 November 1, 2024 (Protocols due by October 25)
Spring 2025 February 20, 2025 (Protocols due by February 13)
May 14, 2025 (Protocols due by May 7)
What is the IRB?
The Institutional Review Board (IRB) is a committee established to review and approve
research involving human subjects. The primary purpose of the IRB is to protect the
rights and welfare of the human subjects. The IRB is responsible for reviewing all
research involving human subjects, ensuring that potential research-related risks
are minimized, and that there is full disclosure so that volunteers can make an informed
decision about whether or not to participate.
What Research Must Be Reviewed by the IRB?
The IRB reviews and monitors human subjects research that fits the definitions of
research and human subject as defined by the Code of Federal Regulations. Research
is a systematic investigation, including research development, testing, and evaluation,
designed to develop or contribute to generalizable knowledge (45 CFR 46.102 (l)).
The IRB considers data gathering activities not to be within its scope of review if
the data is used for non-research purposes, such as institutional evaluation, and/or
if it will not result in presentation or publication. Such activities, including but
not limited to course evaluations or alumni surveys, are not typically within the
scope of the IRB review. A human subject is defined by Federal Regulations as “a living
individual about whom an investigator (whether professional or student) conducting
research obtains (1) information or biospecimens through intervention or interaction
with the individual, and uses, studies, or analyzes the information or biospecimens,
or (2) obtains, uses, studies, analyzes, or generates identifiable private information
or identifiable biospecimens.” (45 CFR 46.102(e)(1)).
Engaging in human subject research without IRB approval has serious ethical implications
and violates federal policies. Students, faculty, and staff are required to submit
IRB applications before embarking on any data collection. Even pilot studies should
be approved by the IRB.
Ramifications for Faculty and Staff
Funding may be withheld: Federal sponsors, and virtually all private sponsors, require
IRB approval as a condition of funding. Sponsors may postpone review of proposals
for which review is not complete or pending at the time of proposal submission.
Many sponsors will not release funds to the University for the investigator's use
without IRB approval. Articles may not be published: Most professional journals
require evidence of IRB approval when considering articles for publication.
Liability issues arising from unapproved research may become the responsibility of
the investigator. Persons conducting unapproved research are deemed to be acting outside
the scope of authority granted them by the University.
Suspension of Research: The University may suspend all research activities for a specified
time frame as a disciplinary measure.
Ramifications for Students
Credit may be withheld: Winthrop may refuse to grant students course credit for research
conducted without IRB approval.
Thesis work may not be accepted.
Degrees may not be awarded for work based on non-IRB reviewed projects.
Articles may not be published: Most professional journals require evidence of IRB
approval when considering articles for publication.
Funding may be withheld: IRB approval is required if you are a participant in a grant
program. These programs will not release funds without IRB approval.
Types of IRB Review
There are three levels of IRB Review (full board, expedited, and determining if exempt
from IRB oversight), determined by the nature of the protocol, level of potential
risk to human subjects, and the subject population. The determination of level of
review applicable to a particular study is made by the IRB. Regardless of the kind
of review, all applications use the same submission form.
Convened IRB Review (Full Board)
Any study involving greater than minimal risk requires a review by the convened IRB.
This includes studies with vulnerable populations and sensitive questions as well
as studies with the possibility of physical risk.
Studies with the possibility of physical risk, such as studies involving exercise,
should include a medical history and review in order to determine whether or not a
person should participate in the study. In some populations, such as the elderly,
it is suggested that consent of a primary family doctor be obtained. In all situations
where exercise is performed, researchers should be trained in handling emergency situations.
Studies assigned to full board review are reviewed by members ahead of time, and then
discussed at the meeting. The Committee then votes on whether or not to approve the
study.
Expedited IRB Review
Only research involving no more than minimal risk to subjects may be considered for
expedited review. An expedited review is conducted by an individual reviewer or a
few reviewers, rather than going to the full board.
Federal guidelines provide categories for expedited review. Examples of categories
include:
Collection of data through noninvasive procedures (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; moderate
exercise, muscular strength testing, body composition assessment, and flexibility
testing where appropriate given the age, weight, and health of the individual.)
Prospective collection of biological specimens for research purposes by noninvasive
means (non-disfiguring hair/nail clippings; 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; mucosal and skin cells collected by buccal scraping
or swab, skin swab, or mouth washings.)
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.
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.
Exempt Review
Research with very minimal risk to human subjects and that meets one of the categories
of exemption as defined by 45 CFR 46 may be exempted from full board review. Although
the project does not require full board approval, the IRB chair or designee must certify
the exemption before the research study begins. If the risks to human subjects appear
questionable or the project does not fit into the federally defined categories for
exemption, then the study must undergo either full or expedited review. Some research
may qualify for an exemption if a limited IRB review is conducted. Limited review
is conducted by an IRB member to ensure that appropriate privacy and confidentiality
protections are in place. An exemption is granted by the IRB upon initial review of
the application. Since this constitutes a review, protocols that are deemed exempt
are effectively “exempt from continuing review.”
How to Request IRB Review
To request review of your proposed research project by the IRB, complete the Request for Review of Research Involving Human Subjects form, Informed Consent form, and other documents as related to your research. The signed and approved PDF
of the protocol, including all attachments, must be submitted to Michele Smith, Grants and Sponsored Research Development, by the submission deadlines published
above in order to be considered at that meeting if Full Board review is required.
Protocols received after the submission deadline will be reviewed at the next scheduled
meeting. Protocols that may qualify for an exemption or that qualify for review under
the expedited process are reviewed on an on-going basis.
Submit a Request for Review of Research Involving Human Subjects form. Forms are available
on the GSRD Forms webpage. Instructions accompany the application. Save a copy of your form in case revisions
are needed. For projects that will require full board review, submit materials by
the deadline indicated on the IRB website.
GSRD will assign the protocol an IRB number that should be used on all correspondence
relating to the study. The IRB will determine the level of review required for each
study. The IRB will conduct its review, and take one of the following actions:
Approval of Research: Research may proceed upon receipt of written IRB approval memo.
Exemption: The study has been found exempt from IRB oversight and research may proceed
upon receipt of written IRB exemption memo.
Revisions or Clarifications Requested: It is common for the IRB to request some changes
to the protocol prior to approval/exemption. Researchers will receive a memo detailing
revisions required. For minor changes, revisions will be reviewed under the expedited
review process. Substantive changes may require full board review at the next scheduled
meeting.
Disapproval: At a full board meeting, the IRB may determine that the research cannot
be conducted as proposed. A disapproval memo will be sent to the researchers, and
research may not proceed.
Expedited or exempt reviews typically take 7 business days. Response times may be
delayed at mid-semester and other peak times.
Studies requiring full board review are scheduled for the next IRB meeting as noted
on the IRB webpage. Correspondence from the IRB is sent to researchers within one week of full board
review.
Researchers have some influence on the length of time between protocol submission
and final approval. Well-prepared applications result in fewer requests for revisions.
Rapid response by researchers to requests for revisions speeds the approval process.
Once the study begins, researchers are responsible to report any adverse events that
may occur. An adverse event is an undesirable and unintended, though not always unanticipated,
injury or physical/emotional consequence to a study participant. Unanticipated problems,
developments within the research activity that suggest a potential for increased risks
to human subjects, must also be reported to the IRB. Use the Adverse Event Report
form on the Forms webpage.
Once a study is approved/exempted, modifications may be submitted. Use the Request
for Modification of Previously Approved or Exempt Protocol form from the Forms webpage to describe the changes requested. Instructions are included on the form. Include
revised surveys, informed consent documents, recruitment materials, and other documentation
as needed. All changes must be approved by the IRB prior to implementation. Modification
review is generally conducted via the expedited process but may require full board
review depending on the revisions requested. Submission of a modification request
does not change the review date for approved protocols.
Scholarly and Journalistic Activities: For purposes of this part, the following activities are deemed not to be research:
Scholarly and journalistic activities (e.g., oral history, journalism, biography,
literary criticism, legal research, and historical scholarship), including the collection
and use of information, that focus directly on the specific individuals about whom
the information is collected (45 CFR 46.102 (l)(1).
Datasets: Public and/or published datasets not subject to Human Subjects Review include those
that are accessible without restriction (e.g., password not needed*) and containing
no readily identifiable, individual information. Examples include:
U.S. Bureau of the Census
National Center for Health Statistic
National Center for Education Statistics
National Election Studies
Public and/or published datasets, accessible without restriction (e.g., password not
needed*), and containing readily identifiable information and where individuals can
reasonably expect this information to be available to the public (examples include
letters to the editor, blogs)
Public and/or published datasets, with restrictions to access, that contain data that
is presented in aggregate form only; thus, individuals cannot be identified. * or in those cases where you must register with a site or organization to gain access,
the registration for login and password must be without qualification – that is, anyone
could register with this site.
Program Evaluation: Program Evaluation is the inquiry into past, present, and potential programs to
understand or clarify their need, working process or impact. There are three major
categories of program evaluation: Needs assessments (formative evaluations) establish
whether or not a program is feasible or necessary; process evaluations determine whether
or not a program's implementation is congruous with its conception; impact evaluations
(summative or outcome evaluations) ascertain whether or not a program meets its goals.
Generally, program evaluations not requiring human subjects review involve data internally
collected and analyzed for the normal course of business. These evaluations' goals
range from simple descriptive statistics to qualitative information, and examples
include program enrollment data, constituent demographics, and outcome analyses. Therefore,
irrespective of human subject involvement, these program evaluations remain internal
and thus do not contribute to generalizable knowledge. However, if a program evaluation
is research and uses human subjects, then it requires approval. Program evaluations
that lead to publishing results in scholarly journals or making presentations outside
your institution likely require approval. The assumption being that publishing/disseminating
the findings generalizes the data. Moreover, evaluations connected to groups' or individuals'
outcomes and affecting the development or implementation of other programs similar
in nature, are generalizable human subjects research and require human subjects review.
Furthermore, an evaluation impacting upon the replication of other programs or services
and the population at large or public policy, should be reviewed and monitored.
Examples of research that might be exempt include:
A study evaluating the effectiveness of a commonly accepted reading curriculum. Researchers
will observe classroom instruction and collect quizzes and class evaluations that
are part of the curriculum and classroom practices.
A study involving interviews with college students (age 18 and older) about their
plans after graduation. The answers to questions asked would present no risks to subjects
if divulged outside the research.
An anonymous survey regarding workplace satisfaction.
A study that involves asking subjects to solve puzzles while listening to various
types of music. Study procedures take less than 2 hours.
Research that involves greater than minimal risk. 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 encountered in daily life or during the performance of
routine physical or psychological examinations or tests.
Research with vulnerable populations. Certain research activities are not eligible
for exempt status because additional protection has been required by federal regulations
for vulnerable populations. Specifically, the following do not qualify for exempt
status: (1) survey or interview of children; (2) observation of the public behavior
of children when investigators interact with the children; (3) interactions with children;
and (4) research involving prisoners except for research aimed at involving a broader
subject population that only incidentally includes prisoners.
For project approved under full board review, federal regulations require continuing
review within one year of the original approval. Near the end of the approval period,
researchers will receive a Request for Status Report. If research is continuing, submit
the Status of IRB Approved Project form from the Forms webpage.
Projects that are reviewed under the expedited review process do not require annual
continuing review but must report if research is ongoing or not. Projects reviewed
under the expedited process are not assigned an expiration date unless a justification
for continuing renewal exists. This will be determined by the IRB.
Projects that the IRB determines to be exempt from further review do not require renewal.
Yes, the IRB requires that participants in research give their consent to take part
in the study. The standard expectation is that participants will sign a document containing
all the elements of informed consent. This document gives potential subjects a clear
and complete description of the study, allowing him/her to judge whether or not to
participate. The informed consent document should provide easily understandable information
in an amount appropriate to the level of risk of participating.
A signed informed consent document may be waived in some circumstances, such as an
online survey, but participants must still give their informed consent to take part
in the research.
Yes, Winthrop uses several standard informed consent templates. These are located
on the Forms webpage.
These templates include all of the information that is required in an informed consent
form:
A statement that the study involves research, an explanation of the purposes of the
research and the expected duration of the subject’s participation, a description of
the procedures to be followed, and identification of any procedures that are experimental;
A description of any reasonably foreseeable risks or discomforts to the subject;
A description of any benefits to the subject or to others that may be reasonably expected
from the research;
A disclosure of appropriate alternative procedures or courses of treatment, if any,
that might be advantageous to the subject;
A statement describing the extent, if any, to which confidentiality of the records
identifying the subject will be maintained;
For research involving more than minimal risk, an explanation as to whether any compensation
and/or medical treatments are available if injury occurs and, if so, what they consist
of, or where further information may be obtained;
An explanation of whom to contact for answers to pertinent questions about the research
and research subject’s rights, and whom to contact in the event of a research related
injury to the subject, if relevant. Typically, questions concerning a research project
should be referred to the Principal Investigator for that project, whereas questions
concerning the rights of human subjects should be referred to Grants and Sponsored Research Development.
A statement that participation is voluntary, that refusal to participate will involve
no penalty or loss of benefits to which the subject is otherwise entitled, and that
the subject may discontinue participation at any time without penalty or loss of benefits
to which the subject is otherwise entitled.
If the research involves the collection of identifiable private information or identifiable
biospecimens, one of the following statements must be included:
A statement that identifiers might be removed from the identifiable private information
or identifiable biospecimens and that, after such removal, the information or biospecimens
could be used for future research studies or distributed to another investigator for
future research studies without additional informed consent from the subject or the
legally authorized representative, if this might be a possibility;
A statement that the subject's information or biospecimens collected as part of the
research, even if identifiers are removed, will not be used or distributed for future
research studies.
Researchers should take great care when obtaining informed consent from individuals
who do not speak English or whose understanding of the language is limited.
Researchers should be fluent in the subject’s language or an interpreter should be
available during the consent process and throughout the subject’s participation as
needed.
Consent forms should be prepared in the language understandable to potential subjects.
While standard procedure is that the informed consent of research participants should
be documented through a written and signed consent form, the requirement for a written,
signed consent form may be waived by the IRB if:
The only record linking the subject and the research would be the informed consent
form and the principal risk would be potential harm resulting from a breach of confidentiality.
Each subject (or legally authorized representative) will be asked whether the subject
wants documentation linking the subject with the research, and the subject's wishes
will govern; or
The research presents no more than minimal risk of harm to subjects and involves no
procedures for which written consent is normally required outside of the research
context; or
If the subjects or legally authorized representatives are members of a distinct cultural
group or community in which signing forms is not the norm, that the research presents
no more than minimal risk of harm to subjects and provided there is an appropriate
alternative mechanism for documenting that informed consent was obtained; or
The research or demonstration project is to be conducted by or subject to the approval
of state or local government officials and is designed to study, evaluate, or otherwise
examine (a)public benefit or service programs; (b)procedures for obtaining benefits
or services under these programs; (c)possible changes in or alternatives to those
programs or procedures; or (d)possible changes in methods or levels of payment for
benefits or services under those programs; and the research could not practicably
be carried out without the waiver or alteration; or
The research involves no more than minimal risk to the subjects, the waiver will not
adversely affect the rights and welfare of the subjects, the research could not practicably
be carried out without the waiver, and whenever appropriate, the subjects will be
provided with additional pertinent information after participation.
Waiving the requirement for a signed, written consent form does not waive the requirement
that subjects be informed of the nature of the research, and that their consent (or
permission of their legal representatives, when appropriate) be obtained. In cases
where a written consent is not used, the researcher should provide the subject with
a statement or cover letter of the research that includes all relevant elements of
informed consent.
Assent is basically the same as consent yet involves minor children (under age 18)
who are not authorized to give legally valid informed consent because of their age.
Assent is written in child friendly language and describes the research participation,
risks, benefits, and other elements of consent. Assent does not waive the requirement for informed consent to be obtained from a parent or legal
guardian.
CITI Training
All members of the research team, including the primary investigator, co-researchers,
research assistants, and/or faculty advisors must complete CITI Human Subject training
before submitting a protocol for IRB review.
Required Training Course for Faculty/Staff: Basic or Refresher
Required Training Course for Undergraduate Students: Undergraduate
Required Training Course for Graduate Students: Basic or Refresher
Instructions to create a CITI account and additional information about CITI can be
found here. Users with an account can log into the CITI Training Site.