Townsend notes the promise of Question 25, which ponders revising the Common Rule "to explicitly state that [field like classics, history, languages, literature, and journalism] are not subject to its requirements."
That seems like a wide open invitation to us, but there are some potential dangers here as well. In 2004, the AHA and Oral History Association worked with HHS on the formulation proposed here (that history does not constitute “research that creates generalizable knowledge”). Unfortunately, the argument prompted some derision from outside the field, from academics who interpreted the phrase to say simply “history is not research.” (As a case in point, the vice president for research at my own university, after a fairly contentious meeting on the subject, wished me well on my “non-research dissertation.”)
We also received a number of complaints from within the discipline. Some historians argue that history does contribute generalizable knowledge, even if it bears little resemblance to the scientific definition of the word. And faculty members at history of medicine departments and in the social science side of history warned that this position undermined both their institutional standing and their ability to obtain grants. They made it clear that however finely worded, stating that history did not constitute research in even the most bureaucratic terms could have some real financial costs to the discipline.
I have just sent in a comment to the AHA blog, suggesting that historians should not be forced to choose between freedom from IRB interference and claiming the title of researchers. Federal law (42 USC 289) does not call for IRBs to review "research," "research that creates generalizable knowledge," or even "research involving human subjects." Rather, it calls for the establishment of IRBs “to review biomedical and behavioral research involving human subjects.”
Historians should propose regulatory language distinguishing between our research and "biomedical and behavioral research" and scrap "generalizable" as a distraction.
Nobody puts Baby in a corner!