AAUP proposal for IRB reform: redefining exempt status

September 21, 2012

The American Association of University Professors (AAUP) recently released a report titled “Regulation of Research on Human Subjects: Academic Freedom and the Institutional Review Board”.  The AAUP’s report is based on an analysis of responses from various professional societies (including LSA) to a July 2011 document released by the Department of Health and Human Services, the ANPRM (advance notice of proposed rule-making), which set out some proposals for IRB reform and asked for feedback. 

Here, I discuss one of the report’s recommendations, which is relevant for linguists, but wasn’t the focus of the LSA’s official response to the ANPRM.  I hope this can start a conversation following up on the earlier (August 2011) discussion on this blog.

The AAUP report recommends that all minimal-risk research on autonomous adults be included in the “exempt” category, not just the short list of procedures (such as survey forms, interviews, and observational research) that is currently included.  This would include much of what currently qualifies for expedited review.  Furthermore, the report proposes that the determination of “exempt” status no longer be subject to IRB review, but rather should be determined by the researchers themselves. 

This is similar to one of the proposals in the ANPRM — a new category of “excused” research to replace the “exempt” category.  This category would similarly expand the scope of the exempt category, but the researcher would still have to “register” their project with the IRB.  The registration forms would then be subject to possible random audit later, but the researcher would be allowed to begin research right away without waiting for approval. 

I think that both proposals would enhance academic freedom and relieve administrative burdens from researchers and IRBs.  Of particular value for linguists is the expansion of the exempt category to include additional types of minimal-risk research.  For example, my own experimental protocols, which consist in adult participants speaking sentences and/or pressing buttons in response to linguistic stimuli, are non-exempt under the current guidelines.  Under either set of revised guidelines, most types of psycholinguistic experiments and other low-risk methods would become exempt.  This would be a welcome change for me, since I would no longer have to wait for approval (which sometimes takes several weeks) every time I need to make a minor change in the protocol.

Would this revised system for exempt research provide adequate protection for participants?  

In a recent email to the Ethics Committee, James Crippen brought up two potential problems regarding the proposed expansion of the exempt category:  (1) how to define low-risk methods for each discipline; and (2) how to take into account subject matter in addition to the actual methods.  

The AAUP solution to both problems is to allow researchers themselves to make those determinations, with the help of a standardized list of exempt methods and the advice of the IRB or a departmental representative as to how discipline-specific methods should fit into the standardized categories.   But does this give too much discretion to researchers? 

I think the idea of having researchers on exempt projects register their projects with the IRB is a good idea, and helps ensure appropriate protection of participants in minimal-risk studies.  Registration of the project forces researchers to explain their procedures and how the rights of participants will be protected (just as in the current system). This would encourage researchers to make a careful, reasoned decision about whether a particular project qualifies as exempt and to seek advice from the IRB or other experts when needed.  I believe that the threat of a random audit would discourage people from inappropriately stretching the definition of exempt status. 

What do you all think?  Do you agree with the proposal to expand the list of exempt categories of research to a larger number of minimal-risk procedures?  Would simple registration of exempt projects be enough to ensure appropriate protection of participants?  If the proposed changes go through, should the LSA provide their own guidelines for how to interpret the new exempt categories with respect to common research protocols in linguistics?

Please post your comments here!

Elaine Francis

Purdue University

Junior Co-Chair, LSA Ethics Committee

New Ethics CORE Initiative

July 31, 2012
The Ethics Committee recently received the following email with information about the initiative and a request for materials. The Ethics CORE library is funded by the National Science Foundation. We are posting the full email here because it contains links that may be relevant to the LSA membership. Their page on language sciences can be found here; it contains links to frequently cited papers on ethics in the language sciences, particularly in applied linguistics and linguistic fieldwork.

Subject recruitment and Facebook

July 25, 2012

Does it seem ethically problematic to recruit experimental subjects by way of a facebook post?  I’m thinking of a project that has permission to recruit by word-of-mouth, by announcements posted to listservs, by posters hung up around campus or elsewhere in the city or passed out in person, etc.  That is, permission for a pretty broad range of recruitment activities is in place.  This is for a low-to-no-risk speech perception experiment.  One could begin the facebook post with “People in X city:” or such, since it’s an in-person experiment.  Facebook seems like a combination of a listserv with word-of-mouth.  Just to clarify:  I haven’t done this, but I’ve considered it.  I’m curious what others think.

Blanket IRB approvals for linguistics

April 11, 2012

There’s been some discussion on a colleague’s FB page about blanket IRB approvals for specific departments.  Apparently, Penn State Center for Language Sciences has one that covers all but ERP studies, as do Ohio State, Stanford, UMass, and possibly Santa Cruz.  Do readers know of any others?  Do you think this is a good thing?


Sample ethics approvals for student research in anthropology

March 27, 2012

Culture Matters blogger Lisa Wynn has posted links to some approvals for ethics clearance at Macquarie University (in New South Wales, Australia). The projects are for a variety of anthropology class projects.

AAA Draft Code of Ethics Posted for Comment

December 10, 2011
From Lise Dobrin
The American Anthropological Association’s Task Force for Comprehensive Ethics Review has recently completed a multi-year process of revising the Association’s Code of Ethics (see the earlier discussion of this topic on this blog). Look here to view the draft code, read the Task Force’s final report, and submit your comments on the draft. The special subcommittee of the AAA Executive Board that is reviewing the Draft Code is chaired by Monica Heller, President-Elect of the AAA and a linguistic anthropologist.

Clearly the Task Force put a great deal of thought into what a code of ethics is and how it can best serve its users. Whether or not it is adopted, the AAA’s Draft Code sets a new benchmark for ethics codes. It represents a whole new kind of document, one that is dynamic and treats readers not simply as ‘adherents’, but as active explorers of ethical issues that concern them. Online users can follow links to resources that expand the discussion of particular segments of the code text, offering further perspectives on the kinds of subtlety and complexity that accompany ethical deliberation in the real world. At a session sponsored by the AAA Committee on Ethics at the AAA Annual Meeting in Montréal, Task Force members half-joked about developing an “ethics code iphone app”. What a terrific idea!

Code of Ethics for Linguists in Forensic Linguistics Consulting Approved

October 27, 2011

In July, the Ethics Committee posted a draft ethics statement for linguists involved in forensic linguistics consulting.The statement was revised in light of comments from the membership and has now been approved by the LSA Executive Committee. The final version is now posted on the LSA website.