Information about IRBs
The relationship of oral history to human subject research regulations has been widely debated since the 1990s, in particular whether oral history should be reviewed by Institutional Review Boards, or IRBs. OHA has played and continues to play a central role in these discussions.
On September 8, 2015, the U.S. Department of Health and Human Services issued a set of recommended revisions to the regulations concerning human subject research. Specifically, it recommended that oral history be explicitly excluded from review by institutional review boards (IRBs), noting that oral history already has its own code of ethics, including the principle of informed consent.
The fact that all of the relevant federal agencies have agreed on this statement represents a big breakthrough in a twenty-year struggle over IRB review of oral history. Since there is a 90-day period during which individuals and organizations may add their own commentary, the Oral History Association has worked with other professional associations to develop a collective response to the recommendations. That commentary can be found on the website of the National Coalition for History.
OHA encourages members to support this development by sending comments. The comment period has been extended to January 6, 2016. Comments can be submitted at the www. regulations.gov website. To reach the correct page, click comment. Once on the regulations page, you will see a “comment now” button on the right side of the page.
OHA executive director Cliff Kuhn has written an overview of the IRB situation leading up to the current recommendations. See Background on the Current HHS Recommendations Concerning IRBs.
Read the History News Network article about IRB review.
To read the entire document, go to Federal Register.
For more information go to the Institutional Review Blog maintained by George Mason University professor Zachary Schrag: Institutional Review Blog.
For specific responses to the recent recommendations, see http://www.institutionalreviewblog.com/2015/09/nprm-proposes-freedom-for-historians.html and http://www.institutionalreviewblog.com/2015/09/nprm-freedom-for-historians-if-they-can.html.
The OHA will continue to monitor and publicize new developments as they take place.
Additional reading on oral history and IRBs: