The federal Office of Human Research Protections (OHRP) recently invited comments on education and training programs for institutional review boards (IRBs), which poses a difficult question for members of our discipline—would a more consistent and effective training program make matters better or worse for oral history?
After following this issue for the past eight years, I am not sure. The inconsistent and uneven application of IRB policies to members of our discipline should be familiar to AHA Today readers. But it is not clear whether these problems arise from ambiguities in OHRP’s regulations or uneven preparation of review board members and staff. If the problem is a matter of training, it seems possible that a better education program could help impose some uniformity from institution to institution.
But consistency is not our only worry. The IRB’s were designed with experimental sciences in mind, and seem to have trouble fitting oral history into their scientific protocols. Our members report that some review boards insist on confidentiality and the destruction of tapes (contrary to the standards of our field), and insist on specific sets of questions (when the give and take of discussion is intrinsic to the method). We do not want to see a more consistent application of such policies. OHRP’s request for comments reinforces my worries that their training mandate would simply reinforce the IRB bias toward the hard sciences. At one point they ask “whether training should be tailored according to an individual’s role in the clinical research process” (emphasis mine), without asking any corresponding questions about other types of research.
Here at the AHA we are still discussing whether we should offer a response, and if so, how we should respond. The request from OHRP lays out some very specific questions—seeking cases where a lack of training led to noncompliance with OHRP policies, and asking who should receive the training and the type of training they should receive. As this suggests, the general direction of the questions suggests that some kind of training is coming. So even though the AHA stands by its policy that oral history should be excluded from IRB review, it is seems hard to ignore the potential effect such a federal-level training program could have.
Given that, the AHA and members who are affected by review boards probably will need to respond to the request for comments. We need to remind OHRP that their mandates have an effect beyond the hard sciences. Ideally, their training program would include a process of discerning research in the humanities from that of the sciences. As ever, I welcome thoughts and suggestions from members. And for members with a direct interest in these issues, I would encourage you to read the request and offer your own comments to OHRP about how more rigorous IRB training might affect your work.