Friday, December 28, 2007

Columbia University Grants Oral History Exclusion

Mary Marshall Clark, director of Columbia University's Oral History Research Office, has announced on H-Oralhist that the university yesterday approved a new policy on IRB review of oral history research. The policy notes that

Oral history interviews, that only document specific historical events or the experiences of individuals or communities over different time periods would not constitute "human subjects research" as they would not support or lead to the development of a hypothesis in a manner that would have predictive value. The collection of such information, like journalism, is generally considered to be a biography, documentary, or a historical record of the individual's life or experience; or of historical events. Oral history interviews of individuals is not usually intended to be scientific or to produce generalizable information and hence is not usually considered 'research' in accordance with the federal regulations or CU policy. Therefore, such oral history activities should not be submitted to the CU IRB for review.

Still covered by IRB jurisdiction are psychological studies that borrow some oral history techniques to test hypotheses. An example might be Kim T. Buehlman, John M. Gottman, and Lynn Fainsilber Katz, "How a Couple Views Their Past Predicts Their Future: Predicting Divorce from an Oral History Interview," Journal of Family Psychology 5 (March/June 1992): 295-318.

I hope Columbia will prove a model for other universities; in lumine tuo videbimus lumen.


Jeffrey Cohen said...


This is what many of us have been saying all along. It is not the methodology that determines whether an activity meets the definition of human subjects research, it is how the information is intended to be used. Not all oral history is human subjects research just as not all medical interventions are human subjects research. The Columbia policy does a good job of this. The only comment I have is that "generalizable" does not just mean statistical generalizability, it also include drawing conclusions that can be generalized beyond the individuals interviewed. For example, an oral history of Iraq war veterans that is intended to determine the affect of using reserve soldiers to fight a war, would be human subjects research. An oral history of Iraq war veterans intended to preserve their experiences and describe a historical event would not.

You should know that Columbia is not the only university that has such a policy. Many universities have similar oral history policies. I have a similar policy that I provide to my clients and several have adopted it.

By the way, just to remind you, oral history that is human subjects research but that does not put subjects at risk generally is eligible for exemption. Institutions decide for themselves how exemption determination are made. ORHP recommends that investigators not make those determinations, but it doesn't have to be the IRB. I have one client, whose program has been accredited by AAHRPP, that has those determinations made on the department level.


Zachary M. Schrag said...

Thank you for this comment. I am glad that you approve of the Columbia policy.

I must take issue with your claim that "this is what many of us have been saying all along."

You addressed the question of oral history in your November 2006 posting, "OHRP and Oral History," and made five recommendations.

You are right that Columbia has implemented one of your recommendations, that institutions "should provide guidance on how to determine if an oral history activity meets this definition. The guidance should include examples of oral history activities that meet the definition and those that don't. I would recommend that this guidance be developed in conjunction with the oral historians at the institution."

However, Columbia has departed from your advice in two highly significant ways:

1. You wrote, "it would be a mistake to allow investigators to make [the] determination [of what is generalizable research] on their own."

Columbia has wisely rejected that argument. It allows historians who use interviews to determine whether they are conducting IRB-regulated research, just as historians who use books can do so.

2. You recommended that universities state that "a 'systematic investigation' is an activity that involves a prospective research plan which incorporates data collection, either quantitative or qualitative, and data analysis to answer a research question. Investigations designed to develop or contribute to generalizable knowledge are those designed to draw general conclusions (i.e., knowledge gained from a study may be applied to populations outside of the specific study population), inform policy, or generalize findings."

Columbia has rejected this definition. Instead, a "systematic investigation" is one that would "support or lead to the development of a hypothesis in a manner that would have predictive value." This is very different; historical research, "like journalism," does not offer predictive value, but it often informs policy.

Since Columbia's new policy exempts pretty much anything a historian is likely to do, your remaining two recommendations, concerning how an IRB should approach non-exempt oral history research, is largely irrelevant.

You claim in your current comment that "Many universities have similar oral history policies. I have a similar policy that I provide to my clients and several have adopted it." As always, I find it hard to discuss these things with you when you make factual claims that cannot be verified. In 2006, the American Historical Association found that

"On almost 95 percent of the university web sites, the only guidance a faculty member or student will find is a passing mention of oral history among the research methods subject to 'expedited' review. This language comes from the insertion of 'oral history' into the federal regulations for review boards in 1998. Most university administrators see these regulations as inviolate law and refuse to accept the recent agreement with federal authorities as a valid interpretation of the rules. To make matters worse, the agreement was further undermined when staff at OHRP issued conflicting and contradictory statements about its meaning shortly after it was issued. The net result—stated explicitly by a few of the review boards—is that even if oral history is excluded from review, only the review boards can decide what is excluded on a case-by-case basis. As a consequence, it appears oral history is still subject to review on most campuses.

"Only eleven of the university web sites discuss the exclusion agreement with OHRP—nine mention the original agreement with the AHA, while seven of them mention the subsequent contradictory guidance from OHRP in fall 2003, and five mention the OHRP's reaffirmation of the exclusion in January 2004."

Robert B. Townsend, "Oral History and Review Boards: Little Gain and More Pain," Perspectives, February 2006.

Are eleven universities "many"? Are any of them your clients?

I'm glad to hear that departmental review has passed AAHRPP scrutiny at "one client," but that client cannot serve as a model for others unless it makes known its policies. Columbia has acted in the scholarly tradition of sharing information freely. Will your client?