Projects are either instructional in nature or not.  Any project going
beyond the enhancement of student knowledge is not instructional in
nature.  Considerations include what is being done with the data and
whether the intent is generalizable knowledge (publications, inferential
statistics, etc).  At the risk of erring on the cautionary side, any
project involving human subjects (survey, interview, students) is
subject to review--funded or not, faculty or student-initiated.

Steve Hoagland
Old Dominion University
Human Subjects IRB