Below are some of the most frequently asked questions from new clients. Please contact us if you require more help.

Every institution engaged in human-subject research conducted or supported by a Federal department or agency is required to designate one or more IRBs under an assurance of compliance. Research using human subjects that is conducted by independent investigators not associated with an institution must also be approved by an IRB. Additionally, when FDA-regulated products are investigated using human subjects, the protocol is subject to review and approval by an IRB.

IRBs are authorized by the U.S. Department of Health and Human Services (HHS). IRBs must be approved and registered by the Office for Human Research Projections (OHRP) of the HHS. IRBs are typically designated by an institution to review research involving human subjects once the institution issues an ‘assurance of compliance’ to the HHS. Such institutions include hospitals, academic medical centers, government units, entities conducting FDA-regulated clinical investigations and others engaged in federally conducted or supported health research activities involving human subjects.

The Office for Human Research Protections (OHRP) is a unit within the Department of Health and Human Services (DHHS) that implements regulations for the protection of the rights, welfare and wellbeing of human subjects on behalf of HHS. OHRP helps ensure human subject safety by maintaining regulatory oversight and by providing guidance, advice and educational programs on ethical and regulatory issues in biomedical research. OHRP is part of the Office of the Assistant Secretary for Health at HHS.

Institutions engaged in non-exempt human subjects research conducted or supported by the HHS must issue a Federalwide Assurance (FWA) of compliance, in which the institution commits to HHS that it will comply with the requirements set for in 45 CFR part 46, which is the HHS Code of Federal Regulations on the Protection of Human Subjects. On behalf of the HHS, the Office for Human Research Protections (OHRP) approves the terms of these written institutional assurances, which constitute binding commitments.

The HHS regulations (45 CFR 46) apply to all research involving human subjects conducted or supported by HHS. The FDA regulations (21 CFR 50 and 56) apply to all research involving products regulated by the FDA, including research and marketing permits for drugs, biological products, and medical devices for human use, regardless of federal funds. When research involves products regulated by the FDA that are funded by HHS, both HHS and FDA regulations apply. While the FDA did not adopt the “Common Rule” Federal Policy that all other federal agencies adopted (including HHS) it did adopt many of its provisions. For the specific differences in regulations, go to: XXXX

HHS regulations define “investigator” as an individual performing various tasks related to the conduct of human subject research activities. They may include physicians, scientists, nurses, administrative staff, teachers, and students, among others. If multiple investigators are conducting the research then one investigator is usually designated the “principal investigator” with overall responsibilities for the study. Investigators have certain responsibilities regarding the ethical treatment of human subjects.

Investigators are responsible for: Obtaining prior approval from an IRB for the research; obtaining and documenting informed consent from the subjects; supplying progress reports to the IRB for continuing review and approval; providing IRB prompt reports if there are any unanticipated problems involving risk to the subjects; keeping certain records as required by the HHS for at least three years after completion of the study.

Informed consent is a fundamental step toward making sure that medical research on human subjects is performed ethically. Human participants in a research project must have enough information to make an informed decision about whether to participate. Consent documents signed by participants should clearly explain the purpose of the study, how long it will take, what the procedure will entail, what parts of the procedure are experimental, what the risks or possible discomforts are, what the benefits might be, a description of alternative procedures, , and what the financial costs (or incentives) are. If participants cannot give informed consent due to age or cognitive incapacity then the patient’s legal guardian must give consent.

An IRB is necessary when research involves humans as participants, and when it has as its goal the generation of universal scientific knowledge. Taking a patient’s blood sample for analysis of medical conditions would not need to be reviewed because its primary goal is educational, rather than scientific. Taking a patient’s blood sample as part of a study on elevated sugar levels in response to stress would require an IRB because its goal is to produce universal or generalized scientific knowledge.