The actual federal guidelines suggest that whether or not anonymous
surveys, which generally fall into the exempt category of research, are to
be reviewed by the IRB is up to the institute. However, some schools that
have an Assurance of Protection Certificate on file with OHPR have stated
that they will review exempt research, and so they must. The types of
research projects that are potentially exempt are listed in the Code of
Federal Regulations, TITLE 45, Part 46. The URL is given below.
Here at Union we currently require all research to be reviewed, but we are
working on a new policy in which the supervising faculty member will sign
off on exempt research. Their signature indicates that they have read the
guidelines and that their student's research project fits the exempt category.
http://ohrp.osophs.dhhs.gov/humansubjects/guidance/45cfr46.htm
Dan Burns
Union College
