Saturday, April 25, 2009

UMKC's Respectful Oral History Policy

The University of Missouri-Kansas City (UMKC) has posted a promising new policy: "Social Sciences IRB and Oral History."

The policy has a number of elements that set it apart from the typical university policy, which seeks to cram oral history into a system designed for medical experimentation. Instead, it adapts only those elements of the medical IRB system that encourage historians to follow their own discipline's ethics and best practices.

I suggest that readers of this blog read the whole policy, but here are some highlights:

1. Respect for Critical Inquiry

As I have written repeatedly on this blog, historians do not take the Hippocratic Oath, and should not promise not to harm the people they interview. Any IRB that imposes the Belmont Report on historians is asking them to forswear their own ethics.

UMKC understands this. Its policy notes that

akin to a journalist or lawyer, an historian is also responsible to a wider public to recover a shared past “as it really happened.” In keeping with the public role of an historian in a democratic society, these responsibilities, especially when conducting narrative interviews, can necessitate a confrontational style of critical inquiry. So while historians do not set out to hurt their interviewees, oral historians are expected to ask tough questions in their interrogation of the past.

2. Respect for Peer Review

The UMKC neither subjects oral historians to the whims of board members unfamiliar with their field, nor does it leave them on their own. Instead, it offers scholars a number of relevant readings, including publications of the Oral History Association, and then encourages them to talk to colleagues knowledgeable about interviewing:

After reviewing these resources on their own, the researcher is strongly encouraged to discuss their research protocol with peers before implementing their research protocol. In some cases, peer review by members of one’s own department would be most useful; in other cases, a researcher might be better served by seeking review from a colleague in a different department.

To foster these kinds of conversations among the faculty, the Social Sciences IRB Subcommittee for Oral History will hold two meetings per semester . . . to discuss “Best Practices” in oral history. Faculty experts in oral history will guide these conversations . . . These meetings are designed to meet the needs of researchers seeking advice and peer review for their research protocols. They are also designed to meet the needs of Chairs and/or designees interested in learning how to advise researchers in their departments to make responsible decisions regarding oral history.

3. Respect for OHRP's Pledge

UMKC takes seriously the carefully negotiated 2003 agreement between the American Historical Association and the Oral History Association and OHRP, even posting a copy on its website. The university elaborates on that agreement:

At UMKC, we draw a distinction between idiographic research that uses oral histories to describe the unique story of some particular social group or individual, which does not constitute “human subjects research”; and nomothetic research that employs oral histories in the hopes of contributing to a general theoretical or comparative debate about the human nature or behavior, which does fall under the category of “human subjects research."

While I confess that the terms idiographic and nomothetic are not in my working vocabulary, I believe they do express a real difference between the ethics of oral historians and those of other scholars. If one is interested in a general theoretical or comparative debate about the human nature or behavior--as many social scientists seem to be--then it makes less sense to single out individuals for potential honor or calumny. Writing about unique individuals or groups changes one's responsibility toward the individuals interviewed.

4. Respect for Researchers

Policies like UCLA's infantilize researchers, making them submit every judgment to an administrator. By contrast, UMKC trusts its scholars:

The bottom line is that the researcher makes these determinations in careful consultation with the Chair of the department or another official designee appropriate to the kind of study being planned. Together this determination is based on shared understanding of all relevant guidelines and their shared expertise in their specialized field of scholarship.

5. Respect for the IRB

Even as it empowers historians, the UMKC policy keeps the IRB involved, making it a resource, rather than an obstacle. Researchers still have to learn something about human subjects regulations, and they must complete a form explaining why they have determined that their policy does not fall under federal regulations.

(The form's demand for an explanation of "no more than 1500 characters" sounds suspiciously bureaucratic, but it's a good length for the presentation of a single idea--about the same as the 150-word limit for a New York Times letter to the editor.)

More importantly, the frequent meetings of the Social Sciences IRB Subcommittee on Oral History suggest that some scholars at UMKC have devoted their time to helping colleagues deal with the real ethical challenges of oral history.

The website explaining the policy notes that it was developed by "a group of faculty and administrators involved with the Social Science Institutional Review Board (SSIRB) . . . with input from members of the SSIRB, the College of Arts & Sciences, and the Faculty Senate at UMKC." I congratulate all the scholars and administrators who developed this innovative system, and I hope it works as well in practice as it reads on the screen.

With this policy, UMKC joins Amherst College, Columbia University, the University of Michigan-Ann Arbor, and the University of Nebraska-Lincoln Policy on a small but growing list of schools that have adopted OHRP's 2003 position removing most oral history research from IRB jurisdiction. Five schools not very many, but it's five more than the AHA could find in February 2006. Who will be number six?

Tuesday, April 21, 2009

Deregulation "Is Not Going to Happen"

Linda Shopes kindly alerts me to the April 20 issue of COSSA Washington Update, the newsletter of the Consortium of Social Science Organizations, which reports on an April 1 meeting of the National Academies’ Board on Behavioral, Cognitive, and Sensory Sciences, at which IRBs were discussed.

Here's the key passage:

Philip Rubin, CEO of Haskins Laboratories in New Haven, CT, and former director of the National Science Foundation’s (NSF) Division of Behavioral and Cognitive Sciences, chairs the Board. He began the session with a review highlighting the difficulties social/behavioral researchers have had with the current system under the Common Rule regulation and its interpretation by campus Institutional Review Boards (IRBs). Complaints have been loud, but mostly anecdotal . . . Once again the bottom line is that despite efforts by Joan Sieber and the Journal of Empirical Research on Human Ethics, which she edits, there are still large gaps in our empirical knowledge of how the system works for social and behavioral scientists.

Rubin was followed by Jerry Menikoff, new head of the U.S. government’s Office of Human Research Protections (OHRP). Menikoff announced that he was all for “flexibility” in the system and that “changes can be made.” He also endorsed conducting more research. He rejected the arguments of the American Association of University Professors and Philip Hamburger of Northwestern University Law School that IRBs violate researchers’ first amendment rights. He acknowledged the importance of expedited review, but stated quite clearly that “removing minimal risk research from the system is not going to happen.”

I don't want to make too much of these comments; an OHRP spokesperson tells me that they were an extemporaneous response to Rubin, and not prepared remarks. Still, I am disappointed. Menikoff's comments suggest a retreat from his earlier concession that "flexibility" often can be code for arbitrary power. And it's a pity for a public official to insist that a given policy "is not going to happen" even as he endorses more research. Wise governance depends on making policies after finding facts, not before.

Friday, April 17, 2009

Macquarie's Innovative Ethics Training

In previous posts and my 2007 essay, "Ethical Training for Oral Historians," I have complained about standardized, medicine-centric ethics training systems like the CITI Program and called for training programs better tailored to individual disciplines.

Lisa Wynn of Macquarie University (also known as MQ) has alerted me to just such a program she created with Paul H. Mason and Kristina Everett. The online module, Human Research Ethics for the Social Sciences and Humanities, has some elements that I find inappropriate. Overall, however, it is vastly superior to the CITI Program and comparable ethics programs I have seen, and it deserves attention and emulation.

Friday, April 10, 2009

Training Day

Peter Klein of the Organization and Markets blog offers a sad account of what it takes for a University of Missouri economist to gain permission to interview entrepreneurs or hand out surveys to corporate executives. Like many scholars across the country, he was directed to an online training system, which demanded that he provide correct answers to questions like the following:

32. The investigator is a 1/8th V.A. employee. She proposes to recruit MU outpatients into a study conducted exclusively at MU facilities. Which of the following groups must approve the research project before participants can be enrolled?

* The MU Health Sciences Center IRB
* The V.A. Research and Development Committee
* Both a. and b.
* Neither a. nor b.

While such knowledge may be of critical importance to health researchers at Missouri, it is irrelevant to social scientists not doing medical work. The lesson Klein takes away from such an experience is not that he must be sure to obey laws and ethics standards while doing his research, but that his campus IRB administrators do not respect him enough to provide relevant ethical training.

Administrators take note: you are making fools of yourselves, and earning your faculty's contempt.

See Comments Oppose New Regulations on Training.