EDINBORO UNIVERSITY OF PENNSYLVANIA

Policy: PROTECTION OF HUMAN SUBJECTS                             Policy No. C026

Supersedes Policy No. C026, Dated July 13, 1993                                

 

Recommended for Approval by: Dr. Robert Weber , Provost and Vice President for  Academic Affairs

Approved by: Dr. Frank G. Pogue, President on Effective Date:  2/1/02

Review Date: As Required

_______________________________________________________________________

INTENT

The Human Subjects Review Board of Edinboro University of Pennsylvania shall be

established for the purpose of protecting the rights and welfare of human subjects involved in research. Human subjects shall be interpreted to include the investigators, participants and the community at large 

 

POLICY

The Human Subjects Review Board shall review, on a continuing basis, proposals for human subjects research to be conducted under the auspices of Edinboro University of Pennsylvania.  Both the administration and the principal investigators shall be advised concerning the acceptability of the proposed project relative to the welfare of the human subjects based on the accepted codes of ethical principles.

Proposals must be submitted for review prior to the initiation of data collection. Each proposal will be evaluated to determine that:

1.      rights and welfare of the subjects are adequately protected;

2.      potential benefits and the importance of the knowledge to be gained from the research outweigh risks to the subjects;

3.      the subjects are informed and their consent is obtained before participation in the research, and that the research utilizes methods that are adequate and appropriate;

4.      confidentiality procedures are sufficient for protecting the subject; and

5.      the researcher possesses the qualifications required for conducting the research.

The Human Subjects Review Board shall operate under the auspices of the Vice President for Academic Affairs .

 

The Review Board may be requested to serve in an advisory capacity if grievances involving threats to the welfare of human subjects should be submitted to the President's office. In order to serve in this advisory capacity, the Board shall be informed of all grievances 'involving matters related to human subjects research.

It is the responsibility of the Review Board to inform the University community of basic procedures for operation and guidelines for reviewing human subject research based upon accepted codes of ethical principles. These basic procedures and guidelines shall be available to assist all researchers within the University in order to provide for the well being of human subjects.

An approval by the Human Subjects Review Board signifies only that the proposal adequately satisfies requirements for the protection of research participants. It does not imply, directly or indirectly, any institutional support or permission to conduct the study.

 

PROCEDURE

Membership and Voting

1.      Human Subjects. Review Board will consist of seven members, including one member who is not an employee of the University and one member currently serving on the Senate Research Committee. All members except the representative from the Senate Research Committee shall serve for a term of three years and may be re-appointed by the President of the University upon recommendation by the Vice President for Academic   Affairs. The representative from the Senate Research Committee will serve only for the time period during which he/she is also a member of the Senate Research Committee.

2.      The chairperson of the Human Subjects Review Board will regularly apprise the Vice President for Academic Affairs of the membership of the Board. When a member's term expires, the chairperson will inform the Vice President of the expiration, including whether or not the member wishes to be considered for an additional term. When an opening occurs on the Board, a call for applications will take place. The Human Subjects Review Board will review the applications and make recommendations to the Vice President for Academic Affairs. The President, based upon recommendations from the Vice President for Academic Affairs, will appoint members of the Board.

3.      Members of the Review Board may not be involved in review of any activity in which they have conflicting interests .

4.      The Human Subjects Review Board shall meet as often as necessary to provide review and advisement, but at least once per semester. Four members of the Board shall constitute a voting quorum. Acceptance of a proposal shall require a minimum of four supporting votes .

 

Levels of Review

All research involving human subjects will be submitted to the chairperson of the Human Subjects Review Board. The chairperson shall determine whether the research is exempt from review or whether a review is required. Research involving the following situations may be exempted from review:

a.      research in common educational settings where students are not identified;

b.      research using educational tests with no identifiers of subjects;

c.      research using surveys or interviews of adults where respondents are not identified and the content is benign;

d.      research involving observations of public behavior; arid

e.      research involving collection, study and use of existing data where  are not identified.

Exemptions do not apply to research involving: prisoners, pregnant women, fetuses and human in vitro fertilization.

Projects requiring review may be reviewed under two levels: Expedited or Full Review.

1.      Research projects that are judged to present only a minimal risk may receive an Expedited Review. "Minimal risk" means that the probability and magnitude of harm or discomfort anticipated in the research are not greater in and of themselves from those ordinarily encountered in daily life or during the performance of routine physical or psychological examination or tests. An expedited review can be made by the chairperson or by one or more reviewers designated by the chairperson from among members of the Human Subjects Review Board. If the proposal is approved, the chairperson will inform the other members of the Board of the approval. If the proposal is not approved, it must be referred to the full Board for disposition.

A collaborative research proposal that has been reviewed and approved by a duly-constituted Human Subjects Review Board from the co-investigator's institution may be handled as an Expedited Review.

2.      All other projects will require Full Review. The Full Review will follow the review protocol outlined below.

a.      The principal investigator of record must be a non-student employee of Edinboro University of Pennsylvania. Student research involving human subjects must be conducted under the direct supervision of a principal investigator. Investigators not affiliated with Edinboro University of Pennsylvania must identify a non-student employee at this institution who is willing to serve as the local contact person.

b.      The principal investigator will submit to the Chairperson of the Review Board one copy of the Human Subjects Review Application including a one-page statement describing the purpose of the research, the population and how it will be selected, and the research method. One copy of any survey, questionnaire, interview questions and/or informed consent forms to be used in the research should also be submitted.

c.      In the application the principal investigator must assure the Review Board that the principles, procedures and guidelines established in the appropriate ethical principles will be followed and that the Review Board has access to pertinent records of research. In addition, the principal investigator should present any information that will aid in evaluating the proposal for compliance with this policy.

d.      Upon receipt of the material, the Review Board chairperson will distribute one copy of the submitted materials to each of the members of the Review Board. The members will independently review the material prior to the meeting of the Review Board.

e.      The principal investigator must be available to discuss the research project at the discretion of the Review Board. The principal investigator will be notified of the Review Board's decision by the chairperson.

 

Review Board Actions

The Review Board may take one of the following three actions in regard to the proposed research project: Approved. Approved Subject to Restrictions. or Disapproved.

1.      When an application has been Approved, the chairperson will prepare a letter of approval and distribute one copy of it to:

a.      the principal investigator;

b.      members of the Review Board; and

c.      the Review Board files.

 A copy of the approval letter must accompany the proposal when it is submitted to the designated administrative officer for processing .

2.      If the protocol is Approved Subject to Restrictions, the chairperson will inform the principal investigator of the restrictions in writing.

The principal investigator must submit documentation of the incorporation of the restrictions to the chairperson prior to final approval. The application will then be processed as an approved application.

Should the principal investigator be unwilling to accept the restrictions, the Review Board will note such and the application will be processed as though it had been disapproved.

3.      If the application is Disapproved, the principal investigator will be informed in writing of the reasons for the disapproval. Every effort shall be made by the Review Board and the principal investigator to meet and discuss those elements of the application which make it unacceptable in order to arrive at a solution. The principal investigator may then withdraw the protocol or submit a revised protocol which will be reviewed as in the initial review procedure.

In those cases in which agreement on an alternative approach cannot be researched, the chairperson will prepare a letter of disapproval and will distribute it with the disapproved application as follows :

a.      the principal investigator;

b.      members of the Review Board;

c.      the appropriate department chairperson;

d.      the appropriate dean;

e.      the Vice-President for Academic Affairs; and

f.        the Review Board's files.

 

Appeals

1.      The principal investigator may appeal the decision of the Review Board when an application has been Disapproved or Approved Subject to Restrictions and mutual agreement cannot be reached as to an acceptable alternative. The Approval or Disapproval of the application would be based on the following:

a.      should a degree of deception and/or withholding of information be necessary for adequate testing of the hypothesis and in the absence of any practical alternative, justification that the potential benefits to  subjects or the importance of the knowledge to be gained outweighs any potential risks that may be present;

b.      the provision of acceptable debriefing procedures ;

c.      the adequacy of facilities and other resources necessary for completion of the study and protection of subjects' rights;

d.      the qualifications of the researcher;

e.      the personal risk to the subject;

f.        the adequacy of procedures for securing informed consent from the subject;

g.      the adequacy of the procedures for maintaining confidentiality ; and/or

h.      the adequacy of measures for the protection of the health, safety , and well-being of the subjects.

 

2.      Upon written notification of appeal from the principal investigator, the Review Board shall name an ad hoc committee of three or more faculty and/or consultants to review the protocol a second time. The ad hoc committee members must be acceptable to both the principal investigator and the Review Board. The application will be reviewed in accordance with the appropriate ethical guidelines. The decision of the ad hoc committee will be binding for both the principal investigator and the Review Board.

 

In the event of disapproval by the ad hoc Review Committee, the research will not proceed as designed. Notification of actions will follow the procedure outlined in the paragraph above .