Human
Research Protection Program: Policy
Expert Review of Protocols
Adopted By: All Campus IRB
Adoption Date: November 10, 2005
Revised: June 7, 2007
Revised: January 22, 2009
Purpose: This document describes how UW-Madison
assures that research protocols are reviewed by individuals with appropriate
scientific or scholarly expertise.
Policy
I. UW-Madison requires that each
research protocol undergo an in-depth review by at least one IRB member with
relevant scientific or scholarly expertise.
Procedure
II. Multiple, Specialized IRBs. To
assure that each protocol receives a review by at least one IRB member with the
requisite expertise, UW-Madison has established multiple IRBs, each of which
specializes in reviewing particular types of research. Protocols are directed
to the IRB with the expertise relevant to the particular protocol.
A. The Education Research IRB (ED IRB) specializes in education research.
It does not review FDA-regulated research or prisoner research. It does not
have appropriate expertise for review of medical research, but may review
research protocols involving minimal risk health-related studies, such as those
involving exercise, tape sensors, and single venipuncture, where medical
training is not necessary for the evaluation of risk to research participants.
Education research focuses on expanding knowledge
and information about the education process, practices that improve academic
administration and academic achievement, the effectiveness of education
programs as well as child development and social adjustment. Included is all
K-12 classroom-based research and educational or learning-related research
conducted in other contexts, such as libraries, religious schools, summer
camps, after school programs, public/private adult service agencies,
public/private treatment centers, workplaces, community based organizations,
and any other learning-related context.
B. The Social and Behavioral Science IRB (SBS IRB) specializes in social
and behavioral science research. The SBS IRB reviews all non-medical
prisoner protocols. It does not review FDA-regulated research. It does not
have appropriate expertise for review of medical research, but may review
research protocols involving minimal risk health-related studies, such as those
involving exercise, tape sensors, and single venipuncture, where medical
training is not necessary for the evaluation of risk to research participants.
The SBS IRB reviews some social and behavioral research involving genetic
testing. See, Review of Social & Behavioral
Genetic Research Protocols Policy.
Social and behavioral research focuses on
individual and group behavior, mental processes, or social constructs and
usually generates data by means of surveys and questionnaires, interviews,
observations, studies of existing records, and experimental designs involving
exposure to some type of stimulus or environmental intervention. It also can
include physiological manipulations and recording, descriptive methods,
laboratory and field experiments, standardized tests, economic analyses,
statistical modeling, ethnography, and evaluation.
C. The HS IRB reviews research protocols involving
medical interventions or procedures where medical expertise is required for
evaluation. Generally, FDA-regulated research is reviewed by this board. Any
research involving experimental devices is reviewed by this IRB.
D. The MR IRB reviews primarily research protocols that
present minimal risk to subjects and that involve medical interventions or
procedures requiring medical expertise or that require knowledge of the health
care setting (e.g., medical records research, research database and tissue
banking projects, survey and interview research, and exemption applications).
The MR IRB can review more than minimal risk research, when the committee
consists of members with the appropriate expertise or ad hoc consultant(s) are
appointed, should additional expertise be necessary.
Examples of types of research activities reviewed
by HS IRB and MR IRB:
§
Therapeutic interventions (e.g., experimental devices, drugs and
biologics)
§
VA research
§
Studies involving devices
§
Research involving medical interventions regardless of whether
therapeutic in nature (e.g., functional MRIs)
§
Clinical trials of FDA approved drugs to test for new indications
§
Observational studies involving collection of medical information
§
Studies involving genetic testing
§
Studies of:
-
Medical records
-
Body materials (biological specimens), such as cells, blood,
urine, tissues, organs, hair, nail clippings, or DNA
-
Medical databases used for research purposes that contain
protected health information
-
Clinical education research (medical school and continuing
medical education)
III. The UW-Madison’s Review of
Prisoner Research Policy requires all federally funded research involving
prisoners to be reviewed by the HS IRB or the SBS IRB. The ED IRB will refer
all protocols involving prisoners, regardless of funding, to the HS IRB or SBS
IRB. The MR IRB may review non-federally funded research involving prisoners
that is expected to present minimal risk to subjects. The MR IRB will consult
with the HS IRB prisoner advocate, as needed, to ensure that prisoners in non-federally
funded research are accorded protections equal to or greater than the
protections outlined in the Subpart C of the DHHS regulations.
IV. Selection of IRB Members. In selecting
IRB members, each IRB looks for individuals who have expertise in the subject
matter areas most frequently represented in the protocols directed to that
IRB.
V. Staff Reviewer
System. The HS IRB and MR IRB use a staff reviewer system. Protocols are
reviewed by professionally trained IRB staff reviewers who are highly
knowledgeable about federal regulations, including the Common Rule, FDA
regulations, VA regulations and HIPAA Privacy Rule. Staff reviewers provide
detailed analysis and summaries of protocols to primary reviewers, the IRB
chair, vice-chair and director and to the full IRB, when appropriate.
VI. Primary Reviewer System. To further
assure that protocols are reviewed by members with the requisite expertise, the
IRBs use a primary reviewer system. Under the primary reviewer system, the IRB
directors are responsible for assigning research protocols to one or more IRB
members with relevant expertise, who are given a complete copy of the materials
submitted by the investigator. The assigned reviewers are responsible for a
detailed analysis of each assigned protocol and one of the assigned reviewers
leads the discussion of the protocol at the full IRB meeting.
If no IRB member has the
relevant expertise, the IRB director (or designee) will request the assistance
of a consultant or refer the protocol to another IRB with the relevant
expertise (See, Sections VII and VIII, below).
VII. Request for Assistance. For exempt
and expedited protocols, IRB members and subcommittees may request advice and
assistance from the IRB chair or other IRB members if additional expertise is
needed to make a determination.
VIII. Referral of Protocols. If an IRB
director determines, based on the description of the research in the protocol application
submitted to the IRB office, that the protocol is not within the IRB’s
jurisdiction, the IRB director will refer the research to an IRB with the
appropriate expertise. The referring IRB will contact the investigator to
notify him or her that the protocol requires transfer to the other IRB and
state the reason for the transfer and will give the investigator the contact
information for the other IRB.
VX. Use of Consultants. If a protocol requires
expertise beyond or in addition to that available on the IRB, an IRB may invite
individuals with competence in special areas to assist in the review of
protocols as described in the IRB Consultants Policy.