The document makes the Smithsonian the latest in a growing number of prestigious research institutions to provide oral historians, journalists, and folklorists explicit permission to do their work without contacting the IRB. Here are the key questions and answers:
6. Are there any examples of activities that aren't considered Human Subjects Research?
The following are specifically excluded from the definition of Human Subject Research and do not need to be reviewed by the IRB:
• interviews used to provide quotes or illustrative statements, such as those used in journalism;
• collection(s) of oral histories and cultural expressions (e.g., stories, songs, customs, and traditions and accounts thereof) to document a specific historical event or the experience of individuals without intent to draw statistically or quantitatively-based conclusions or generalizations;
• gathering of information from a person to elucidate a particular item (or items) in a museum collection;
• gathering of information from a person to assess suitability for and/or supplement a public program, publication, or cultural performance; or
• survey procedures, interview procedures, or observations of public behavior that are conducted for Smithsonian internal purposes only, the results of which will not be published or presented in a public setting (e.g., at conferences or professional meetings).
7. I think my project is an "oral history" and doesn't need to be reviewed by the IRB. How can I be sure?
The hallmark of an oral history is that it stands alone as a unique perspective rather than an item of data that can be qualitatively analyzed to reach a general conclusion or explanation. If your intention is to interview people who have a unique perspective on a particular historical event or way of life, and you also intend to let the individuals' stories stand alone, with no further analysis, the research is most likely oral history and you do not need to have the research reviewed by the IRB. However, if the surveys or interviews are conducted with the intention of comparing, contrasting, or establishing commonalities between different segments or among members of the same segment, it is safe to say your research will be regular survey/interview procedures, because you will be generalizing the results and your research may need IRB review.
While it is welcome, I can't say this is the most elegant policy. It is hard to track a researcher's intentions and post-interview decisions, rather than his or her conduct of the interviews themselves. And wouldn't a journalist gathering reactions to an event be "comparing, contrasting, or establishing commonalities between different segments or among members of the same segment"?
By contrast, Princeton University distinguishes among types of interviews based on the likelihood that the people being interviewed will understand that they are speaking for the record.