Institutional review board
||The examples and perspective in this article may not represent a worldwide view of the subject. (March 2014)|
An institutional review board (IRB), also known as an independent ethics committee or ethical review board, is a committee that has been formally designated to approve, monitor, and review biomedical and behavioral research involving humans. They often conduct some form of risk-benefit analysis in an attempt to determine whether or not research should be done. The number one priority of IRBs is to protect human subjects from physical or psychological harm. In the United States, the Food and Drug Administration (FDA) and Department of Health and Human Services (specifically Office for Human Research Protections) regulations have empowered IRBs to approve, require modifications in planned research prior to approval, or disapprove research. IRBs are responsible for critical oversight functions for research conducted on human subjects that are "scientific," "ethical," and "regulatory."
Although designed to protect the rights and welfare of the research subjects, IRBs have been criticized by bioethicists for conflicts of interest resulting in lax oversight. As of 2005, the for-profit Western Institutional Review Board claimed to conduct the majority of reviews for new drug submissions to the FDA. In a 2006 study of 575 IRB members at university medical centers, over one-third reported industry financial ties and over one-third admitted they "rarely or never" disclosed conflicts of interest to other board members. A 2009 sting operation by the Government Accountability Office led Coast IRB to shut down after approving the fake product "Adhesiabloc", called "the riskiest thing I’ve ever seen on this board" by one of the IRBs not approving the fake product.
In the United States, IRBs are governed by Title 45 Code of Federal Regulations Part 46. These regulations implement provisions of the National Research Act of 1974, for example defining IRBs and requiring them for all research that receives support, directly or indirectly, from what was the Department of Health, Education, and Welfare at the time, and is now the Department of Health and Human Services (HHS). IRBs are themselves regulated by the Office for Human Research Protections within HHS. IRBs were developed in direct response to research abuses earlier in the 20th century. Two of the most notorious of these abuses were the experiments of Nazi physicians that became a focus of the post-World War II Doctors' Trial, and the Tuskegee Syphilis Study, a project conducted between 1932 and 1972 by the U.S. Public Health Service on black men in rural Alabama. The goal of the experiment was to understand the long term effects of syphilis on the human body. Men with syphilis were studied but were never told that they had syphilis. Many men died, and many of their family members also contracted syphilis with no knowledge of the risk they faced. This was an abusive case by the Public Health Service. Title 21 Part 56 has additional requirements for IRBs that oversee clinical trials of drugs involved in new drug applications.
While IRBs can be more inclusive or restrictive, under the statute, exemptions to IRB approval include research activities in which the only involvement of human subjects will be in one or more of the following categories:
A. Research conducted in established or commonly accepted educational settings, involving normal educational practices, such as
- research on regular and special education instructional strategies, or
- research on the effectiveness of or the comparison among instructional techniques, curricula, or classroom management methods.
B. Research involving the use of educational tests (cognitive, diagnostic, aptitude, achievement), survey procedures, interview procedures or observation of public behavior, unless:
- information obtained is recorded in such a manner that human subjects can be identified, directly or through identifiers linked to the subjects; and
- any disclosure of the human subjects' responses outside the research could reasonably place the subjects at risk of criminal or civil liability or be damaging to the subjects' financial standing, employability, or reputation.
C. Research involving the use of educational tests (cognitive, diagnostic, aptitude, achievement), survey procedures, interview procedures, or observation of public behavior that is not exempt under paragraph (B)(2) of this section, if:
- the human subjects are elected or appointed public officials or candidates for public office;
- federal statute(s) require(s) without exception that the confidentiality of the personally identifiable information will be maintained throughout the research and thereafter.
D. Research involving the collection or study of existing data, documents, records, pathological specimens, or diagnostic specimens, if these sources are publicly available or if the information is recorded by the investigator in such a manner that subjects cannot be identified, directly or through identifiers linked to the subjects.
E. Research and demonstration projects which are conducted by or subject to the approval of department or agency heads, and which are designed to study, evaluate, or otherwise examine:
- public benefit or service programs;
- procedures for obtaining benefits or services under those programs;
- possible changes in or alternatives to those programs or procedures; or
- possible changes in methods or levels of payment for benefits or services under those programs.
F. Taste and food quality evaluation and consumer acceptance studies:
- if wholesome foods without additives are consumed or
- if a food is consumed that contains a food ingredient at or below the level and for a use found to be safe, or agricultural chemical or environmental contaminant at or below the level found to be safe, by the Food and Drug Administration or approved by the Environmental Protection Agency or the Food Safety and Inspection Service of the U.S. Department of Agriculture.
Naming and composition
Although "IRB" is a generic term used by the FDA and HHS, each institution that establishes an IRB may use whatever name it chooses. Regardless of the name chosen, the IRB is subject to the FDA's IRB regulations when studies of FDA-regulated products are reviewed and approved. At one time such a committee was named the "Committee for the Protection of Human Subjects".
Originally, IRBs were committees at academic institutions and medical facilities to monitor research studies involving human participants, primarily to minimize or avoid ethical problems.
Today, some IRB reviews are conducted by for-profit organizations known as 'independent' or 'commercial' IRBs. The responsibilities of these IRBs are identical to those based at academic or medical institutions, and they are governed by the same federal regulations. The composition of an IRB for the FDA's requirements is set in 21 CFR 56.107.
- (a)1 The IRB must have at least five members.
- (a)2 The members must have enough experience, expertise, and diversity to make an informed decision on whether the research is ethical, informed consent is sufficient, and appropriate safeguards have been put in place.
- (a)3 If the IRB works with studies that include vulnerable populations, the IRB should have members who are familiar with these groups. It is common for an IRB to include an advocate for prisoners when considering research that involves them.
- (b)1 The IRB should include both men and women, as long as they aren't chosen specifically for their gender.
- (b)2 The members of the IRB must not be all of the same profession.
- (c) The IRB must include at least one scientist and at least one non-scientist. These terms are not defined in the regulations.
- (d) The IRB must include at least one person who is not affiliated with the institution or in the immediate family of a person affiliated with the institution. These are commonly called "Community Members."
- (e) IRB members may not vote on their own projects.
- (f) The IRB may include consultants in their discussions to meet requirements for expertise or diversity, but only actual IRB members may vote.
To vote on a proposal, more than half of the members of the board must be present and there must be a nonscientist present. Exceptions for expedited review are available, where only the chair of the committee or a designee reviews research, but these are relatively narrow.
Purpose and use
IRBs are most commonly used for studies in the fields of health and the social sciences, including anthropology, sociology, and psychology. Such studies may be clinical trials of new drugs or devices, studies of personal or social behavior, opinions or attitudes, or studies of how health care is delivered and might be improved.
The purpose of an IRB review is to assure, both in advance and by periodic review, that appropriate steps are taken to protect the rights and welfare of humans participating as subjects in a research study. IRBs attempt to ensure protection of subjects by reviewing research protocols and related materials. IRB protocol review assesses the ethics of the research and its methods, promotes fully informed and voluntary participation by prospective subjects capable of making such choices (or, if that is not possible, informed permission given by a suitable proxy), and seeks to maximize the safety of subjects.
According to International Conference on Harmonisation - Good Clinical Practice (ICH-GCP) an IRB/IEC should safeguard the rights, safety, and well-being of all trial subjects. Special attention should be paid to trials that may include vulnerable subjects, such as pregnant women, children, prisoners, the elderly, or persons with diminished comprehension. The primary ethical principles in human subjects review are outlined in the Belmont Report, and include "respect for persons", "beneficence", and "justice." The IRB may only approve research for which there is a bona fide informed consent process for participants, for which the risks to subjects are balanced by potential benefits to society, and for which the selection of subjects presents a fair or just distribution of risks and benefits to eligible participants.
The IRB/IEC should obtain trial protocol(s)/amendment(s), written informed consent form(s) and consent form updates the investigator proposes for use in the trial, subject recruitment procedures (e.g., advertisements), written information to be provided to subjects, investigator's brochure, available safety information, information about payments and compensation available to subjects, the investigator's current curriculum vitae and/or other documentation evidencing qualifications, and any other documents the IRB/IEC may need to fulfill its responsibilities.
The IRB/IEC should review a proposed clinical trial within a reasonable time and document its views in writing, clearly identifying the trial, the documents reviewed and the dates for the following:
- approval/favourable opinion
- modifications required prior to its approval/favourable opinion
- disapproval/negative opinion
- termination/suspension of any prior approval/favourable opinion
According to ICH GCP, the IRB/IEC should consider the qualifications of the investigator for the proposed trial, as documented by a current curriculum vitae and/or by any other relevant documentation the IRB/IEC requests.
According to ICH GCP the IRB/IEC should conduct continuing review of each ongoing trial at intervals appropriate to the degree of risk to human subjects, but at least once per year.
The IRB/IEC may request more information than is outlined in paragraph 4.8.10 be given to subjects when, in the judgment of the IRB/IEC, the additional information would add meaningfully to the protection of the rights, safety and/or well-being of the subjects. When a nontherapeutic trial is to be carried out with the consent of the subject's legally acceptable representative (see 4.8.12, 4.8.14), the IRB/IEC should determine that the proposed protocol and/or other document(s) adequately addresses relevant ethical concerns and meets applicable regulatory requirements for such trials. Where the protocol indicates prior consent of the trial subject or the subject's legally acceptable representative is not possible (see 4.8.15), the IRB/IEC should determine that the proposed protocol and/or other document(s) adequately addresses relevant ethical concerns and meets applicable regulatory requirements for such trials (i.e., in emergency situations). The IRB/IEC should review both the amount and method of payment to subjects to assure neither presents problems of coercion or undue influence on the trial subjects. Payments to a subject should be prorated and not wholly contingent on completion of the trial by the subject.
According to ICH GCP (good clinical practice), the IRB/IEC should ensure the information regarding payment to subjects, including the methods, amounts, and schedule of payment to trial subjects, is set forth in the written informed consent form and any other written information to be provided to subjects. The way payment will be prorated should be specified.
While the federal regulations and Belmont principles were formulated with biomedical and social-behavioral research in mind, the enforcement of the regulations, the examples used in typical presentations regarding the history of the regulatory requirements, and the extensiveness of written guidance have been predominantly focused on biomedical research.
Numerous complaints by investigators about the fit between the federal regulations and its IRB review requirements as they relate to social science research have been received. Broad complaints range from the legitimacy of IRB review, the applicability of the concepts of risk as it pertains to social science (e.g., possibly unneeded, over-burdensome requirements), and the requirements for the documentation of participants' consent, i.e., consent forms). Social scientists have criticized biomedical IRBs for failing to adequately understand their research methods (such as ethnography). In 2003, the Office for Human Research Protections (OHRP), in conjunction with the Oral History Association and American Historical Association, issued a formal statement that taking oral histories, unstructured interviews (as if for a piece of journalism), collecting anecdotes, and similar free speech activities often do not constitute "human subject research" as defined in the regulations and were never intended to be covered by clinical research rules.
Other federal agencies supporting social science have attempted to provide guidance in this area, especially the National Science Foundation. In general, the FAQ assures IRBs that the regulations have some flexibility and rely on the common sense of the IRB to focus on limiting harm, maximizing informed consent, and limiting bureaucratic limitations of valid research.
- Clinical trial
- Ethics committee (European Union)
- Unethical human experimentation in the United States
- IRB: Ethics & Human Research
- Informed consent
- Data monitoring committee
- Declaration of Helsinki
- Office for Human Research Protections
- Ethical problems using children in clinical trials
- National Commission for the Protection of Human Subjects of Biomedical and Behavioral Research
- Inside the Ethics Committee
- The Office of Human Research Protection. Institutional Review Board Guidebook. "Chapter 3, Section A: Risk/Benefit Analysis.” pp. 1-10  Retrieved May 30, 2012
- "Should Society Allow Research Ethics Boards to Be Run As For-Profit Enterprises?". PLOS Medicine. Retrieved 2014-03-28.
- Caroline McNeil (2014-03-03). "Debate Over Institutional Review Boards Continues as Alternative Options Emerge". Jnci.oxfordjournals.org. Retrieved 2014-03-28.
- Elliott, Carl (2005-12-13). "Ethics for sale". Slate.com. Retrieved 2014-03-28.
- —By Carl Elliott. "Poor Reviews". Mother Jones. Retrieved 2014-03-28.
- Mundy, Alicia (22 April 2009). "Coast IRB, Caught in Sting, to Close". The Wall Street Journal.
- [dead link]
- "FDA Approves Nonexistent Product from Nonexistent Company for Human Testing | Food Freedom". Foodfreedom.wordpress.com. 2011-01-17. Retrieved 2014-03-28.
- "Code of Federal Regulations". HHS.gov. 2010-01-15. Retrieved 2014-03-28.
- See 7 C.F.R. § 1c.101
- "PART 56 - INSTITUTIONAL REVIEW BOARDS". Food and Drug Administration (United States). 28 June 1991. Retrieved 2009-05-12.
- International Conference on Harmonisation of technical requirements for registration of pharmaceuticals for human use. "Good Clinical Practice". Retrieved 27 September 2012.
- Ritchie, Don; Shopes, Linda (2003). Oral History Excluded from IRB Review: Application of the Department of Health and Human Services Regulations for the Protection of Human Subjects at 45 CFR Part 46, Subpart A to Oral History Interviewing. Oral History Association. Archived from the original on 17 January 2008. Retrieved 31 December 2008.. See also An Update on the Exclusion of Oral History from IRB Review (March 2004).
- Frequently Asked Questions
-  Thaddeus Mason Pope, "Multi-Institutional Healthcare Ethics Committees: The Procedurally Fair Internal Dispute Resolution Mechanism," 31 Campbell Law Review 257-331 (2009).
Fairchild, A. L., Bayer, R., (1999). Uses and Abuses of Tuskegee. American Association for the Advancement of Science, 284, 919-921.
Enfield, K. B., & Truwit, J. D. (2008). The Purpose, Composition, and Function of an Institutional Review Board: Balancing Priorities. Respiratory Care, 53, 1330- 1336.
- "Human Research Report" - a monthly newsletter for IRBs
- Office for Human Research Protections (OHRP) at HHS
- IRB: Ethics & Human Research – a peer-reviewed journal of The Hastings Center
- Drug Industry Human Testing Masks Death, Injury, Compliant FDA, Bloomberg News Special Report, November 2, 2005
- Ethics for Sale: For-profit ethical review, coming to a clinical trial near you, Carl Elliott and Trudo Lemmens, Slate, December 13, 2005