Fieldwork Classes and the IRB

I am teaching a traditional field methods class this semester. We are working with a speaker of a Tibeto-Burman language. The class has both undergraduate and graduate students in it. Late last semester I called Yale’s IRB regarding the question of whether the class required IRB clearance, and if so, which forms I should use (at my university we have separate forms for student research and class projects). I am reproducing my IRB’s response and their rationale here.

The class was determined to be not subject to IRB review. That is, it did not come under the definition of “research involving human subjects” from the regulatory perspective. (Remember that this is distinct from “exempt”, which is a category of review.)

There were two reasons for the determination, as I understand it. The first was that it is a class activity, and most class activities are considered not to come under these rules. The relevant passage in the regulations is here:

§46.101 To what does this policy apply?

(b) Unless otherwise required by department or agency heads, research activities in which the only involvement of human subjects will be in one or more of the following categories are exempt from this policy:

(1) Research conducted in established or commonly accepted educational settings, involving normal educational practices, such as (i) research on regular and special education instructional strategies, or (ii) research on the effectiveness of or the comparison among instructional techniques, curricula, or classroom management methods.

In this case, even though publications are likely to come out of the project, this clause was deemed to cover field methods classes.

The second reason was that the class is studying the structures of language, not human behavior. That is, we will be doing research about the properties of the language, and not the speaker. The crucial point here is the definition of a human subject:

(f) Human subject means a living individual about whom an investigator (whether professional or student) conducting research obtains …

Since we are not gathering information about our consultant, but about her language, the regulations don’t apply.

Note: I present this material here as a case study. I am not saying that on the basis of this determination, no field methods classes need to be approved by IRBs. Instructors for field methods classes need to check with their own IRBs about how they interpret these regulations. Furthermore, in my class I make sure that the students receive training in consent procedures and other areas of ethical regulation, and our consultant is an employee of the university for this semester (that is, we employ our consultant as an junior instructor in the class) – this may also have an effect on how the regulations are interpreted.

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6 Responses to Fieldwork Classes and the IRB

  1. cahillm says:

    For clarification, is the definition of “human subject” one from the university, or Federal regulations?

  2. Susan Fischer says:

    But don’t you need demographic information about the consultant?

  3. Claire says:

    The definition of human subjects is the one in the regulations.
    Susan, I think this might be where the fact that the consultant is an instructor comes in. It’s true that we will be asking her some demographic questions (though probably not as much as I would for other field-based fieldwork).

  4. sylvialreed says:

    There’s also the issue of what to do if/when information about the consultant does come up–for instance, if the consultant volunteers personal information in the course of telling a story or explaining how to say something. It seems to me that this kind of issue is accounted for in a reviewed project that is determined to be exempt (as it has been determined that such occurrences will not cause harm to the consultant), but perhaps not in the case of projects determined to be not subject to review. Any thoughts on this?

  5. Lise Dobrin says:

    As I was reminded in a discussion with my IRB director the other day, deeming something “not research” and deeming it “normal educational practice” are not the same thing. If the sole purpose of the activity is to educate students (as one can somewhat justifiably claim in the case of a field methods course) then you/a board can avoid oversight by saying it’s not research. On the other hand, if you’re experimenting with a new pedagogical method that is basically comparable to the kinds of adjustments that teachers make in their classrooms all the time, that could be considered “normal educational practice.” So the two designations do not overlap. In the latter case you are acknowledged to be doing research; in the former case you’re not.

    With a field methods course, the question to throw back at your board when they tell you you it’s “not research” is: “Well then what if we discover things we later want to write research articles about?” Some boards will answer “well in that case…” and have you submit a protocol to cover the contingency.

    I think Silvia’s asking an important question if we’re backing away from regulatory definitions but still care about research ethics. It’s a problem that arises any time the speaker is not just responding but really in control (like whenever they record a “text”). Even if *your interest* is in grammar and lexicon, those features will be carried by real, voiced, contentful speech, which will now be in your possession, dissociated from the person who produced it. Does the speaker want that stuff circulating around any which way subject only to your fancy? That’s where issues of consent and the potential for “disresepect to persons” start to arise. When I taught field methods last year we gave the speaker a release form — at the end of the semester — where he got to review what we recorded over the past 13 weeks and decide whether we could keep and continue to use the recordings for research (he opted yes), and whether he wanted his name associated with them (he opted no). That was not a requirement imposed by our board, but simply an effort on our part to do the right thing.

  6. Claire says:

    Regarding the possibility of writing articles associated with the work in the class, that did come up, and we were told that it wouldn’t be a problem unless the focus of the class changed considerably.

    I think this class is a really good example of why researchers need to think about ethics beyond the IRB. In this case, the IRB is pretty categorical that they don’t need to review the protocols. But there are ethical issues arising through the class (though for the most part they are issues that I think would not be covered by ethics review anyway). For example (and I will need to be a bit circumspect so as to protect the privacy of our consultant), our consultant spent a lot of time in refugee camps before coming to the US. That was a very difficult time for her, and talking about it is quite confronting and upsetting to some to the students. Now, this is not something that has come up directly in the strict research context, but it is something that I (as instructor with some duty of care to both students and the consultant) need to monitor.

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