NPRM: Will Political Science Interviews Require Review?

What do we know about interview research under the NPRM?

Whatever its final provisions, the new Common Rule seems bound to be much harder to follow than, say, Canada’s TCPS2. The proposed rule is full of cross references from one section to the next, and often to other documents, such as Subpart D or the Belmont Report. This makes it hard to figure out what it says about any given form of research.

Here’s what I’ve been able to figure out about one form: interview research. My sense is that the NPRM proposes to eliminate IRB review for the vast majority of conversations between consenting adults, but it may unintentionally impose review on projects that do not merit it.

NPRM: Forgotten Folklore

The NPRM proposes “to explicitly exclude oral history, journalism, biography, and historical scholarship activities that focus directly on the specific individuals about whom the information or biospecimens is collected.” Not listed is another scholarly discipline that also focuses on specific individuals: folklore. Why?

NRC Report: Liberate Oral History

For historians, the most exciting passage in the new National Research Council report—the passage that had me cheering out loud—is the recommendation that the Common Rule be amended to explicitly exclude historical interviews, as well as other forms of information gathering that do not constitute “human-subjects research specifically in the biomedical, behavioral, and social sciences.”

NIH Policy Makes Interviewing Children Easier

Susan Ridgely, assistant professor of religious studies at the University of Wisconsin at Oshkosh, finds that IRBs can cause trouble for qualitative researchers who want to talk with children, but that IRB review has some benefits. Moreover, since the NIH started calling for children to be included in medical studies, she is finding it easier to get IRB permission to speak to children.

[Susan B. Ridgely, “Doing Ethnography with Child Consultants: Making the IRB Process Work.” Journal of American Folklore 125, no. 3 (2012): 474–485.]

Smithsonian Frees Oral History, Journalism, and Folklore

The Smithsonian Institution has posted a document entitled "HUMAN SUBJECTS RESEARCH FAQs." Although undated, the document appears, from its metadata, to have been last modified on 11 June 2010.

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.