Do Oral Historians Need an IRB Approval?

In 1974, the National Research Act, set the Institutional Review Board, also known as the IRB, with the purpose of reviewing biomedical and behavioral research involving human subjects. It basically was put in place to protect human subjects. It gave the IRB the authority to approve, disapprove or require modification of projects involving human subjects.  It was charged by the federal government with protecting the rights, interests and dignity of human research subjects.  Its constructive process for oral historians and the principles and practices developed within biomedical and behavioral frameworks have been applied to a more humanistic form of inquiry

The subject of IRB oversight policies in research has been an issue of great concern to the oral historians for a number of years. This is because many universities and research organizations that accepted federal research funds, required oral historians to present their research documents/protocols to the IRB for final approval. Before approval was passed, delay and ambiguity was felt by research investigators which in the long run would impede the speed of the research.

The oral historian family also felt that their terms and conditions needed for approval violated principles and best practices of oral history in the name of addressing nonexistent risks.  One such violation included the requirement to destroy interviews after a period of time, which directly contradicted the principle of narrator ownership of copyright and best practices on archival preservation.

But in the year 2019, oral historians could now breathe a sigh of relief as there was a revision to the US Department of Health and Human Service policy for protection of human research subjects known as Common Rule, that excluded Oral History from IRB review through a strict definition of research. (final regulation under Code of Federal Regulations Part 46 Section 46:102.) It defines research as being a systematic investigation including research development, testing, evaluation designed to contribute to generalized knowledge.  The following activities are deemed not research under scholarly and journalistic activities such as oral history, journalism, literary criticism.

On the other hand, studies using participant observation and ethnographic studies in which investigators gather information from individuals to understand the beliefs customs for practice of either the individuals or a community to which they belong, would fall under generalizable knowledge and therefore would not be excluded from IRB review under the new rules.  

So, the long and short of it is, oral historians don’t need an IRB approval as long as the oral history study falls under scholarly and journalistic activities that collect and use information about specific individuals themselves.

Despite these changes to exclude OH from the IRB oversight, oral historians must continue to hold themselves to the highest professional and ethical standards.

That’s it for this blog post, leave a comment in the comment section below and keep us in mind for all your oral history transcription needs.

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