October 25, 2011
The Association reiterated its long-held opinion that oral history research should be fully excluded from institutional review board (IRB) oversight in a letter submitted by AHA Executive Director Jim Grossman to the federal Office of Human Research Protections today. The letter explains:
Historians who use interview methods focus on eliciting information about particular experiences of the past, and their work suffers irreparable harm when forced into rubrics developed to treat human beings in a general (or “generalizable”) way. The standards and procedures of Institutional Review Boards are alien to oral history research, and over the past decade we have compiled ample documentation of the misapplication of such rules to research projects in the field.
The letter goes on to describe some of the difficulties reported by historians in recent years “as a fundamental violation of the principles of oral history research, and a violation of the First Amendment rights of our members.”
Building on the clear evidence of harm caused to oral history research by the past application of inappropriate rules and regulations, the letter goes on to challenge other aspects of the recent federal proposal that would seemingly extend rules for medical privacy to wide swaths of other information. Grossman’s letter encourages the agency to consider that “As you prepare the final regulations, please remember that information exists in a time horizon that extends beyond the brief life cycle of a biomedical research study. These materials should be protected in a way that will make them available to serve as a source for future historical research.”
You can read the full text of the letter, and learn more about the federal proposal to change IRB rules in these past blog posts: Oral History and Information Risk: A Response to the Federal Proposal (October 17, 2011); Getting Free of the IRB: A Call to Action for Oral History (August 1, 2011); and The Feds and IRBs: Your Opportunity to Weigh in (November 6, 2007).
Submit a Comment
We encourage you to write HHS with your own thoughts and observations on the issues raised by the proposal; you still have a day left before the deadline (October 26, 2011). Submit a comment online here by clicking “Submit a Comment” on that page.
This response was developed after extensive consultation with the presidents of the American Historical Association, the members of the AHA’s Research Division, Jacqueline Jones (vice president for professional issues), Alice Kessler-Harris (President of the Organization of American Historians), Linda Shopes and Rina Benmayor (former presidents of the Oral History Association), Donald A. Ritchie (Historian of the U.S. Senate), and Zachary Schrag (George Mason University and author of Ethical Imperialism).