Re: Department-Level IRBs Robert Bienkowski 18 Oct 2005 11:28 EST

I agree with John Baumann and Nancy Peterson that this is a bad idea. (In addition, there is the matter of what to do about the boxes that are checked on your institution's FWA.)

However, there is one special set of circumstances in which this can work and that is for protocols that are deemed (by whoever is empowered by your SOPs to do it) exempt from IRB review. There really is no such thing as "exempt research:" The regs only say that some types of research are exempt from complying with 45CFR46. But this does not mean that the institution has no responsibility to oversee the research or protect research subjects who might be enrolled in these studies. Under these circumstances, it would be very appropriate to specify that the work should be carried out according to the APA Standards.

Regards
Bob Bienkowski

--
Robert S Bienkowski, PhD
xxxxxx@att.net

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