1. Is it human subjects research?
Research + Human Subject = IRB Review
Research is defined as "a systematic investigation, including research, development, testing and evaluation, designed to develop or contribute to generalizable knowledge." 45 CFR 46.102(d)
Human Subject means a living individual about whom an investigator conducting research obtains:
- Data through intervention or interaction with the individual
- Identifiable private information
- Intervention includes both physical procedures by which data are gathered (for example, venipuncture) and manipulations of the subject or the subject's environment that are performed for research purposes.
- Interaction includes communication or interpersonal contact between investigator and subject.
- Private information includes information about behavior that occurs in a context in which an individual can reasonably expect that no observation or recording is taking place, and information which has been provided for specific purposes by an individual and which the individual can reasonably expect will not be made public (for example, a medical record). Private information must be individually identifiable (i.e., the identity of the subject is or may readily be ascertained by the investigator or associated with the information) in order for obtaining the information to constitute research involving human subjects.
2. Research subject to oversight by the Food and Drug Administration (FDA)
If the research involves any of the following, FDA regulations 21 CFR 50 & 56 apply and require IRB approval prior to implementation:
- Any use of a drug in research other than the use of an FDA approved drug in the course of medical practice;
- Any use of a medical device in studies where the purpose is to determine the safety or effectiveness of the device; or
- Data will be submitted to or held for inspection by FDA as part of a marketing permit.
At CHNw the IRB Office determines whether a project qualifies as human subjects research. If you do not believe your activity meets either of the above definitions for human subjects research please complete the Non-Human Subjects Research Determination Form and submit it to IRB@ecommunity.com. Please note that no activity can begin until a determination letter is received from the IRB office.
Non-Human Subjects Research (NHSR) Form