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.