Hope College Frees Oral History

Hope College, a liberal arts college in Michigan, has posted Oral History Research Guidelines that give substantial leeway to oral history projects:'

EXCLUDED
If the intent is to interview informants who have a unique perspective on a particular historical event or way of life and/or the investigator intends to let the informants' stories stand on their own as a "testimony" or in an archive, with no further analysis, the research is most likely Oral History that is EXCLUDED from HSRB review. Hope College's HSRB has determined that this research WOULD NOT constitute "research" as defined in 45 CFR 46.102(d). Nevertheless, the treatment of participants in Oral History Research must conform to the standards of the Oral History Association. If your project falls into this category, please complete the simple HSRB Oral History Project Registration Form instead of completing a full HSRB application.

NOT EXCLUDED
If, unlike in projects described above, the investigator conducts the surveys or interviews with the intention of comparing, contrasting, or establishing commonalities between different segments or among members of the same segment, it is clear that the investigator will draw generalized conclusions from the results. This type of research is most likely Oral History that is NOT EXCLUDED from HSRB review. Because such research is designed to develop or contribute to generalizable knowledge (e.g., designed to draw conclusions, inform policy, or generalize findings), Hope College's HSRB has determined that it WOULD constitute "research" as defined in 45 CFR 46.102(d). For example, knowledge gained from a study may be applied to populations outside of the specific study population. If your project falls into this category, please go to HSRB's Decision Tree to determine what type of HSRB application to submit.

Whether or not your project is excluded, Hope College believes ethics and ethical principles should govern all of our educational and research activities.

The HSRB Oral History Project Registration Form is indeed a simple, one page form, and it seems designed to distinguish between genuine oral history projects and other forms of interaction, allowing the former to proceed without further IRB involvement.

Unfortunately, the policy is less clear than other universities' about what triggers IRB jurisdiction. The policy refers to both "generalized conclusions" and "conclusions" (without a modifying adjective), while the registration form mentions "general conclusions." Are these the same thing? And why does the registration form suggest that work that "informs policy" counts as research, when this does not appear as a factor in the Belmont Report, the Common Rule, or any federal guidance?

I suspect that someone at Hope--perhaps a committee--has been trying to reconcile the contradictory statements put out by OHRP over the years. Good luck with that.