Type of Review Requested
WHY THIS INFORMATION IS IMPORTANT TO THE IRB:
This information assists the DOH IRB in determining the appropriate level of review. Per Federal regulation, unless the research meets the specified criteria for Expedited Review or Exemption, studies are reviewed at a convened meeting of the full IRB Committee. The Investigator should be aware of the criteria for review and indicate which level of review the study may require. The IRB makes the final determination regarding appropriate committee review.
INVESTIGATOR HELP:
There are two levels of review: Full Committee (Standard) Review and Expedited Review.
Full Committee (Standard) Review: Full committee or standard review is the review of a research proposal by a quorum of IRB Committee members attending a convened meeting. This type of review is necessary for all initial and continuing reviews of research except where Expedited Review is appropriate under Federal regulations. Proposals that do not meet the criteria for expedited review are always reviewed by a quorum of the full, convened IRB committee. Expedited Review is a term defined by federal regulations and is only applicable when research is no more than minimal risk and the research fits into one or more of the expedited review categories.
Criteria for Approval by Full Committee Review
Full Committee Review is necessary for all research that does not qualify for Exempt or Expedited review categories. The Investigator can help facilitate the approval of an application by considering these requirements in the development of the IRB application. Specifically, the Committee may only approve an application when it finds that:
1. Risks to subjects are minimized: (i) by using procedures which are consistent with sound research design and which do not unnecessarily expose subjects to risk, and (ii) whenever appropriate, by using procedures already being performed on the subjects for diagnostic or treatment purposes.
2. Risks to subjects are reasonable in relation to anticipated benefits, if any, to subjects, and the importance of the knowledge that may reasonably be expected to result. In evaluating risks and benefits, the IRB Committee will consider only those risks and benefits that may result from the research (as distinguished from risks and benefits of therapies subjects would receive even if not participating in the research). Investigators should distinguish procedures done as part of standard of care from those done for research purposes and explain how the research portion may impact the risks and benefits to the participant.
3. Selection of subjects is equitable. In making this assessment the IRB Committee will take into account the purposes of the research and the setting in which the research will be conducted and should be particularly cognizant of the special problems of research involving vulnerable populations, such as children, prisoners, pregnant women, mentally disabled persons, or economically or educationally disadvantaged persons.
4. Informed consent will be sought from each prospective subject or the subject's legally authorized representative, in accordance with, and to the extent required by federal regulations.
5. Informed consent will be appropriately documented in accordance with, and to the extent required by federal regulations.
6. When appropriate, the research plan makes adequate provision for monitoring the data collected to ensure the safety of subjects.
7. When appropriate, there are adequate provisions to protect the privacy of subjects and to maintain the confidentiality of data.
Expedited Review: The Secretary of Health and Human Services (HHS) has established and published a list of categories of research that may be reviewed by the IRB through an expedited review procedure. An Expedited Review means the proposal does not have to be reviewed by the IRB at a convened meeting. An Expedited Review consists of a review of the research by the appropriate IRB Chairperson or his/her designee. In reviewing the research, the reviewer may exercise all of the authorities of the full IRB Committee, except that the reviewer may not disapprove the research. The reviewer may refer the application to the Full Committee for a Standard Review if warranted. Research that presents greater than minimal risk to subjects does not qualify for expedited review.
Criteria for Approval of Expedited Review
Federal regulations allow the IRB to review certain applications on an expedited basis if they meet specified criteria. Use of expedited review by the IRB is restricted to those applications that both (i) present no more than minimal risk to human subjects; and (ii) fulfill one of the nine specific categories described below.
1. Research Must Present No More than Minimal Risk.
Minimal risk means that the probability and magnitude of harm or discomfort anticipated in the research are not greater in and of themselves than those ordinarily encountered in daily life or during the performance of routine physical of psychological examinations or tests. An example of minimal risk is the risk of drawing a small amount of blood from a healthy individual for research purposes (because the risk of doing so is no greater than the risk of doing so as part of a routine physical examination).
The Expedited Review procedure may not be used where identification of the subjects and/or their responses would reasonably place them at risk of criminal or civil liability or be damaging to the subjects’ financial standing, employability, insurability, reputation, or be stigmatizing, unless reasonable and appropriate protections will be implemented so that risks related to invasion of privacy and breach of confidentiality are no greater than minimal. Additionally, the expedited review procedure may not be used for government classified research involving human subjects.
2. Research Must Fall into Specific Category.
In addition to being determined to be minimal risk, all expedited studies must also fit into one of the following nine categories. The categories apply regardless of the age of subjects, except as noted. The nine categories should not be deemed to be of minimal risk simply because they are included on the list. Inclusion on the list merely means that the activity is eligible for review through the expedited review procedure when the specific circumstances of the proposed research involve no more than minimal risk to human subjects.
The following expeditable categories pertain to both initial and continuing IRB Expedited Review:
(1) Clinical studies of drugs and medical devices only when condition (a) or (b) is met. (a) Research on drugs for which an investigational new drug application (21 CFR Part 312) is not required. (Note: Research on marketed drugs that significantly increases the risks or decreases the acceptability of the risks associated with the use of the product is not eligible for expedited review.) (b) Research on medical devices for which (i) an investigational device exemption application (21 CFR Part 812) is not required; or (ii) the medical device is cleared/approved for marketing and the medical device is being used in accordance with its cleared/approved labeling.
(2) Collection of blood samples by finger stick, heel stick, ear stick, or venipuncture as follows: (a) from healthy, nonpregnant adults who weigh at least 110 pounds. For these subjects, the amounts drawn may not exceed 550 ml in an 8 week period and collection may not occur more frequently than 2 times per week; or (b) from other adults and children, considering the age, weight, and health of the subjects, the collection procedure, the amount of blood to be collected, and the frequency with which it will be collected. For these subjects, the amount drawn may not exceed the lesser of 50 ml or 3 ml per kg in an 8 week period and collection may not occur more frequently than 2 times per week.
(3) Prospective collection of biological specimens for research purposes by noninvasive means.
Examples: (a) hair and nail clippings in a nondisfiguring manner; (b) deciduous teeth at time of exfoliation or if routine patient care indicates a need for extraction; (c) permanent teeth if routine patient care indicates a need for extraction; (d) excreta and external secretions (including sweat); (e) uncannulated saliva collected either in an unstimulated fashion or stimulated by chewing gumbase or wax or by applying a dilute citric solution to the tongue; (f) placenta removed at delivery; (g) amniotic fluid obtained at the time of rupture of the membrane prior to or during labor; (h) supra- and subgingival dental plaque and calculus, provided the collection procedure is not more invasive than routine prophylactic scaling of the teeth and the process is accomplished in accordance with accepted prophylactic techniques; (i) mucosal and skin cells collected by buccal scraping or swab, skin swab, or mouth washings; (j) sputum collected after saline mist nebulization.
(4) Collection of data through noninvasive procedures (not involving general anesthesia or sedation) routinely employed in clinical practice, excluding procedures involving x-rays or microwaves. Where medical devices are employed, they must be cleared/approved for marketing. (Studies intended to evaluate the safety and effectiveness of the medical device are not generally eligible for expedited review, including studies of cleared medical devices for new indications).
Examples: (a) physical sensors that are applied either to the surface of the body or at a distance and do not involve input of significant amounts of energy into the subject or an invasion of the subject=s privacy; (b) weighing or testing sensory acuity; (c) magnetic resonance imaging; (d) electrocardiography, electroencephalography, thermography, detection of naturally occurring radioactivity, electroretinography, ultrasound, diagnostic infrared imaging, doppler blood flow, and echocardiography; (e) moderate exercise, muscular strength testing, body composition assessment, and flexibility testing where appropriate given the age, weight, and health of the individual.
(5) Research involving materials (data, documents, records, or specimens) that have been collected, or will be collected solely for nonresearch purposes (such as medical treatment or diagnosis). (NOTE: Some research in this category may be exempt from the HHS regulations for the protection of human subjects. 45 CFR 46.101(b)(4). This listing refers only to research that is not exempt).
(6) Collection of data from voice, video, digital, or image recordings made for research purposes.
(7) Research on individual or group characteristics or behavior (including, but not limited to, research on perception, cognition, motivation, identity, language, communication, cultural beliefs or practices, and social behavior) or research employing survey, interview, oral history, focus group, program evaluation, human factors evaluation, or quality assurance methodologies. (NOTE: Some research in this category may be exempt from the HHS regulations for the protection of human subjects. 45 CFR 46.101(b)(2) and (b)(3). This listing refers only to research that is not exempt).
Request for Exemption: A Principal Investigator may request the DOH IRB review a proposal to determine if it qualifies for Exemption. Investigators do not have the authority to make an independent determination that research involving human subjects is exempt and must contact the IRB concerning the status of proposed research or changes in ongoing research. Therefore, an application must be submitted for review in order for the IRB to make the determination that the research is exempt from further IRB review. To qualify for Exemption from full committee or expedited IRB review, the research must meet one of the categories indicated on the IRBWise application form and in Department policy at http://flpublichealthethics.net/index.php/eng/researchers/policies/irb_review_procedures
IRB POLICIES AND PROCEDURES:
IRB Policy 4.3 - IRB Review of Human Subjects Research (Exempt)
IRB Policy 4.4 - IRB Review of Human Subjects Research (Expedited)
IRB Policy 4.5 - IRB Review of Human Subjects Research (Full Committee)
It is the policy of the DOH IRB that all human subjects research activities under its jurisdiction be reviewed according to the criteria described in the Federal regulations.
FEDERAL REGULATIONS/GUIDANCE:
Title 45 CFR 46
§46.109 IRB review of research.
(a) An IRB shall review and have authority to approve, require modifications in (to secure approval), or disapprove all research activities covered by this policy.
(b) An IRB shall require that information given to subjects as part of informed consent is in accordance with §46.116. The IRB may require that information, in addition to that specifically mentioned in §46.116, be given to the subjects when in the IRB's judgment the information would meaningfully add to the protection of the rights and welfare of subjects.
(c) An IRB shall require documentation of informed consent or may waive documentation in accordance with §46.117.
(d) An IRB shall notify investigators and the institution in writing of its decision to approve or disapprove the proposed research activity, or of modifications required to secure IRB approval of the research activity. If the IRB decides to disapprove a research activity, it shall include in its written notification a statement of the reasons for its decision and give the investigator an opportunity to respond in person or in writing.
(e) An IRB shall conduct continuing review of research covered by this policy at intervals appropriate to the degree of risk, but not less than once per year, and shall have authority to observe or have a third party observe the consent process and the research.
Title 45 CFR 46
§46.110: Expedited review procedures for certain kinds of research involving no more than minimal risk, and for minor changes in approved research.
(a) The Secretary, HHS, has established, and published as a Notice in the Federal Register, a list of categories of research that may be reviewed by the IRB through an expedited review procedure. The list will be amended, as appropriate, after consultation with other departments and agencies, through periodic republication by the Secretary, HHS, in the Federal Register. A copy of the list is available from the Office for Protection from Research Risks, National Institutes of Health, DHHS, Bethesda, Maryland 20892.
(b) An IRB may use the expedited review procedure to review either or both of the following:
(1) some or all of the research appearing on the list and found by the reviewer(s) to involve no more than minimal risk,
(2) minor changes in previously approved research during the period (of one year or less) for which approval is authorized.
Under an expedited review procedure, the review may be carried out by the IRB chairperson or by one or more experienced reviewers designated by the chairperson from among members of the IRB. In reviewing the research, the reviewers may exercise all of the authorities of the IRB except that the reviewers may not disapprove the research. A research activity may be disapproved only after review in accordance with the non-expedited procedure set forth in §46.108(b).
(c) Each IRB which uses an expedited review procedure shall adopt a method for keeping all members advised of research proposals which have been approved under the procedure.
(d) The Department or Agency head may restrict, suspend, terminate, or choose not to authorize an institution's or IRB's use of the expedited review procedure.