Yes, that's a good point, but would the 'or' in the cateogory #4
description make a difference here?  I'm assuming that the oral histories
have been placed in a public library, or other such archive.  (Presumably
at that time, there was no intention to do research with this data.)

In my understanding, a project in this cateogry may be eligible for
exemption, category #4, if:
the sources are publicly available
OR
if no identifiers are recorded by the investigator

So, if the oral history is already in the public domain (even with
identifiers), I would understand this project may be eligible for the
exemption.

Our IRB would consider some of these oral history projects to need
prospective review (rather than the 'existing data' exemption) because they
involve 'research' or an 'intent to contribute to generalizable knowledge'
(per 45 CFR).  Consider a distinction between simply providing historical
information to the public on WWII veterans, vs. comparing, drawing
conclusions and making generalizations among a number of these veterans'
stories.  If the latter is intended prior to initiation of the oral
histories, then the project would need IRB review before doing the
interviews.  This would result in the veterans knowing the whole purpose of
the activity, and allowing them to consent to the research.

Teri Grosz, IRB Director
Office of Sponsored Programs
North Dakota State University

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