The Mission of the FSU Human Subjects Committee is to protect the welfare of human subjects participants by compliance with the federal regulations governing the protection of human subjects, and facilitating the research efforts of FSU faculty, students and staff.
Research Using Human Subjects
The Florida State University is committed to the ethical principles for the protection of human subjects in research as set forth in the Belmont Report of the National Commission for the Protection of Human Subjects of Biomedical and Behavioral Research (1979)
The ethical principles are:
- Respect for persons - which includes the requirement of a voluntary informed consent process
- Beneficence – which entails an obligation to protect persons from harm by minimizing risks and maximizing benefits
- Justice – which requires that selection of subjects be fair and equitable and that particular care be taken when working with populations (i.e. children, decisionally impaired) whose status puts them in a vulnerable position.
Human Subjects Research - Identifying Intent – Is this Project Research?
Federal regulations give the Institutional Review Board ("IRB"), also known as the Human Subjects Committee ("HSC") the authority to oversee research involving human subjects. The IRB has no regulatory authority or jurisdiction to oversee activities that are legitimately classified as something other than research. Institutions prefer to have non-research activities handled by an entity other than the IRB, so that the IRB can focus its time and resources on managing its fundamental mission.
As defined by DHHS 45.CFR 46.102 (d), "Research" means a systematic investigation, including research development, testing and evaluation, designed to contribute to generalizable knowledge. When evaluating a specific project, it is helpful to focus on two key elements:
- the project involves a systematic investigation, and
- the design – meaning the goal, purpose, or intent – of the investigation is to develop or contribute to generalizable knowledge. Having only one of these properties means that the activity is not “research” and should not be handled as such.
One helpful question to aid in determining whether a project is "research", is whether the investigators desire or may desire to publish the results of their project in a journal, or present some aspect of the project at an academic meeting. While this is often a practical key factor in determining intent involving a project, there is a distinction between publication that is merely educational in intent, such as a medical journal that may contain an article that discusses information that is not the result of a research activity versus an article that addresses results of a research activity.
After the project has been designated "research" as defined by the federal regulations, the next step is to determine whether the project involves "human subjects". 45 CFR 46 (f) provides:
Human Subject means a living individual about whom an investigator (whether professional or student) conducting research obtains (1) data through intervention or interaction with the individual, or (2) identifiable private information. Intervention is defined as both physical procedures by which data are gathered (i.e. venipuncture) and manipulations of the subject or the subject’s environment that are performed for research purposes. Interaction includes communication or interpersonal contact between an investigator and subject. Private Information must be individually identifiable (the identity of the subject is or may be ascertained by the investigator or associated with the information) in order for obtaining the information to constitute research involving human subjects.
Some examples of human subjects research:
- Interviewing cancer survivors about coping techniques
- Questionnaires about dating behaviors among college students
- Surveys about shopping preferences in rural communities
- Moderate exercise activities and venipuncture of individuals to determine certain depletions
- Music therapy intervention to determine whether it affects pain levels in a hospital environment.
Human subjects research does not include, as examples:
- Surveys for evaluating the performance of faculty, staff, and students, or other studies for internal institutional use only (not a "research" activity)
- Oral history of New Orleans jazz artists and memories of post-WWII era (information is not gathered for "generalizable knowledge").
- Secondary analysis of publically availably data, such as reviewing US Census data (not "human subjects" – de-identified data).
Institutional Review Board – The Human Subjects Committee
An Institutional Review Board ("IRB") is the formal name for a Human Subjects Committee. Established pursuant to federal regulations, the IRB is a committee composed of scientists and laypersons who review all proposed FSU human subjects research to ensure that the safety and welfare of subjects are protected. All human subjects research requires review and approval by an IRB prior to subject recruitment and data collection, and prior to the use of extant data or private information. The IRB at FSU is known as the Human Subjects Committee ("HSC"). The FSU HSC members have the responsibility for reviewing all research involving human subjects conducted by FSU faculty, students, or staff, regardless of the source of funding.
Assurance and Jurisdiction of the IRB
FSU’s assurance with the federal government specifies that all research activities involving human subjects, and all other activities which even in part involve such research, regardless of funding source or sponsorship, must be reviewed by the IRB (Human Subjects Committee) if one or more of the following apply:
- the research is sponsored by FSU
- the research is conducted by or under the direction of any employee, faculty, staff, student, or agent of FSU in connection with his or her institutional responsibilities
- the research is conducted by or under the direction of any employee, faculty, staff or agent of FSU using any property or facility of this institution
- the research involves the use of FSU’s non-public information to identify or contact human research subjects or prospective subjects.
The Office of Research
The FSU Office of Research provides the professional and administrative support to the HSC. The staff members provide support by performing recordkeeping duties, maintaining a database in order to address research protocol and compliance issues, and providing training regarding federal regulation requirements. The staff also serves as a resource for investigators and HSC members, and has delegated authority to determine the initial appropriate level of review required for each research proposal submitted for review.
The Review Process for Human Subject Studies
Federal regulations divide human subjects research into three categories according to the level of risk posed to subjects. For all projects involving human subjects, researchers must submit an application for HSC (IRB) review. (Note that researchers may also need approval from FSU Sponsored Research Services or from other oversight Committees, such as FSU Radiation Safety, before the research project may commence.) The categories of review are as follows:
Exempt: To qualify for this category, the research must fall into one of six exemption categories by the HSC. (http://www.hhs.gov/ohrp/humansubjects/) These categories present the lowest amount of risk to potential subjects because they generally involve ether collection of anonymous or publically available data, or conduct of the least harmful research experiments. Examples of research that qualify as exempt are:
- anonymous surveys
- research involving normal educational practices
- analyses of discarded pathological specimens without personal identifiers
Important Distinction: It is the policy of FSU to review and approve research proposals that meet the definition of “exempt”. FSU uses the expedited review process for exempt protocols. The Principal Investigator does not make the decision whether a protocol qualifies as exempt; the HSC/staff has the authority to determine whether a proposal meets the exempt requirements. Investigators are still required to document informed consent, and undergo continuing review of exempt research protocols.
Expedited review: To qualify for this category, research must fall into one of the nine federal defined categories of research that may be reviewed through an expedited review process. (http://www.hhs.gov/ohrp/policy/exprev.html) These categories involve collection of samples and data in a manner that is not anonymous and that involves no more than minimal risks to subjects. Some examples qualifying for expedited review are:
- Studies involving collection of hair, saliva, or dental plaque samples
- Studies of blood samples from healthy volunteers
- Analysis of voice recordings
- Studies of existing pathological specimens with personal identifiers
This type of review process involves a subset of the full committee membership, delegated this authority by the Chair, to independently evaluate the protocol, and when all reviewers concur, the protocol is approval. At FSU, expedited review is performed by two HSC members, and the Chair.
Note: Reviews via the expedited process usually take approximately three weeks.
Full Committee Review: this category of review is reserved for research proposals that involve greater than minimal risk or a particular vulnerable population as defined in the regulations. Examples include:
Invasive physiological or medical research
Research where there is a risk that confidentiality could be violated and if breached could result in potential criminal or civil liability or damage to a subject’s financial standing, employability, or reputation.
Research involving prisoners
Important Distinction: It is the policy of FSU that all research involving vulnerable populations, such as prisoners, children, decisionally impaired, pregnant women and fetuses, neonates be reviewed by the full committee. Note that protocols involving the deception of research subjects, or other potentially vulnerable populations such as students or economically disadvantaged persons may be reviewed by the full committee.
Full committee meetings are held monthly at a time and location that is subject to change from semester to semester. Information regarding the time and place of meetings may be obtained by contacting the HSC Office, and is posted on the website. Protocols that require review at a convened full committee meeting must be received in the FSU HSC office no later than 5:00 PM deadline day, which is posted on the website.
Principal Investigators and faculty advisors may attend the full committee meeting if requested by the primary reviewer for a protocol, and may provide information to the members; however, they may not be present during the final discussion and vote. HSC members may not participate in the review and approval process of their own protocols.
Note: Full committee review process takes approximately six weeks.
HIPAA and the Privacy Rule: the Privacy Rule of the Health Insurance Portability and Accountability Act (HIPAA) took effect April 14, 2003. HIPAA regulates the protection of private health information for individuals. The law’s Privacy Rule provides standards for the use and disclosure of all individually identifiable health information obtained from a covered entity. FSU is considered a "hybrid entity" with the FSU Thagard Student Health Center. Health Information that contains any of the 18 identifiers defined by HIPAA are considered to be protected health information ("PHI") subject to HIPAA regulations. To access this information, all researchers must obtain either an individual’s written authorization to access their protected health information, or obtain an approval of a waiver of authorization from an IRB/HSC or Privacy Board. Use of data from the FSU Thagard Center must receive prior HSC approval.
Other Review Requirements: When the HSC review process is complete, you will receive written notification of the Committee’s action. Please read all correspondence carefully because it may request additional information or describe conditions associated with the Committee’s action. The approval period for a protocol can be for no longer than 12 months (365 days) from the date of the review, but may be less than 12 months, depending on the perceived risks to the research subjects.
Adverse Events: An adverse event is a serious, undesirable, and unintended result involving risks to research participants or others. Adverse events must be promptly reported in writing to the IRB/HSC Chair, and a form is provided on this webpage. The Investigator must provide a description of the adverse event and state whether or not changes are needed in the protocol and the informed consent process. These revisions must be reviewed by the full committee. If the events are determined to place participants at increased risks, the Chair may request resubmission of the protocol for full committee review. If the committee determines that the research participant may be placed at an immediate risk, the Committee has the authority to suspend or terminate approval of a protocol, requiring the immediate cessation of data collection from research participants. The Investigator will be notified of the Committee action, and the Chair shall contact the appropriate University officials, sponsors, and/or OHRP or FDA as required.
Amendments or Changes to the Protocol: When an Investigator desires to amend or change a protocol, he or she should contact the FSU HSC prior to implementation of any amendments or changes for review and approval. A protocol change may affect the risks involved with a study, in addition to adverse events, unanticipated problems, or complaints about the research – all of which should be reported to the HSC. A written description of proposed changes to the protocol, informed consent process and/or research instruments must be submitted to the HSC for review and approval.
Minor changes proposed to previously approved protocols ( i.e. number of participants) must be reviewed by the HSC Chair. All other proposed modifications (major changes) will be reviewed using the same process used for the review of the original protocol. Only when it is necessary to eliminate apparent immediate hazards to research participants, may, according to the federal regulations, an Investigator be permitted to modify an approved protocol without the prior review and approval of the IRB; however, the IRB must be promptly informed of the change upon implementation.
Continuing Review (Renewals): All protocols approved by the FSU HSC are subject to continuing review at intervals appropriate to the degree of risk, but not less than once in the 12 months following approval. At FSU, this is called the Renewal process. If the Principal Investigator does not receive a form for request for continuing review (renewal) within one month prior to the expiration date of the current FSU HSC approval, a request for the form should be made by contacting the HSC office.
If the HSC approval of a protocol expires before it has been re-reviewed, the protocol shall be suspended. While in a suspended status, new subject recruitment must cease, and interventions under the research protocol must be halted. The only exception to this requirement is when there are concerns for the safety or well-being of the research subjects. In such a case, the Investigator must contact the HSC promptly. The suspension will be removed when and if the protocol is re-approved by the HSC.
The HSC, as a courtesy, sends out a written reminder to the Principal Investigator that the approval date is approaching expiration, and a renewal form is attached to the notice. However,it is the responsibility of the Principal Investigator to apply for renewal prior to the expiration date of the HSC approval. If the protocol has not been re-approved, then the approval expires and data collection must cease. The Principal Investigator will receive a written notification of the HSC’s review and decision for continuing a research protocol when the review process is complete. If the protocol has been re- approved, the notice will be labeled as "Re-Approval".
Closing a Study at FSU: If an Investigator desires to close or terminate a study on or before the approval expiration date, he/she must submit a Study Closure Report Form to be received by the IRB staff.