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OHA Members Encouraged to Comment on Human Subject Research Revisions

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.

OHA has posted an overview of the IRB situation leading up to the current recommendations. See Background on the Current HHS Recommendations Concerning IRBs.

The fact that all of the relevant federal agencies have agreed on this statement represents a major 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.

We encourage individual members to support this development ​by sending comments to HHS on the regulations 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.  Should you need it, the docket ID for this is HHS-OPHS-2015-0008.

The National Coalition for History document provides a brief overview should you need some talking points for your comments.

The deadline ​for comments is January 62016.

The OHA Council will continue to monitor and publicize new developments as they take place.

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