Human Research Protections News Brief FALL 2013 Inside this issue: Waiver of Written (Signed) Informed Consent An Institutional Review Board (IRB) is able to waive the requirement to obtain signed informed consent in two situations: The only record linking the participant and the research would be the consent document; The principal risk would be potential harm resulting from a breach of confidentiality; Each participant will be asked whether the participant wants documentation linking the participant with the research, and the participant's wishes will govern; and The research is not a clinical investigation subject to FDA regulations. Waiver of Written (Signed) Informed Consent 1 OR The research presents no more than minimal risk of harm to participants and The research involves no procedures for which written consent is normally required outside of the research context. What is a clinical investigation? A clinical investigation as any experiment that involves a test article and one or more human subjects and that either is: 1) subject to requirements for prior submission to the FDA, OR 2) Not subject to requirements for prior submission to the FDA under these sections of the Federal Food, Drug, and Cosmetic Act, but the results of which are intended to be submitted later to, or held for inspection by, the FDA as part of an application for a research or marketing permit. Researchers interested in obtaining a waiver of written (signed) informed consent should make sure that their research qualifies for one of the above options, and should address how the research qualifies for each of the option's requirements in the Appendix P of the electronic IRB Application. HRP Staff Contact Information AND Education & Reminders: Expiration of IRB Approval 2 APPLICABLE FEDERAL REGULATIONS OHRP: 45 CFR 46.117 FDA: 21 CFR 50 & 21 CFR 56 In cases where the documentation requirement for informed consent is waived, the IRB often requires the researchers to provide participants with a written statement regarding the research. This written statement requires prospective IRB approval. The template Study Information Sheet can be used as a guide. The written statement is presented to the prospective subject as part of the informed consent process. As part of the verbal consent process, the researcher should; Explain the study to the prospective subject including a discussion of the study purpose, procedures, risks, benefits, compensation, and alternatives to participation, but above all, that participation is completely voluntary; Provide the prospective subject the Study Information Sheet for review, when applicable; Allow the potential subject sufficient time to ask questions; Assure that the prospective subject understands the research procedures (e.g., ask open ended questions); Answer the prospective subject questions and obtain the subject’s verbal agreement to participate in the research. A Note About Online Research: When administering the Study Information Sheet via an online method, consent is assumed if the participant starts the study procedures (e.g., online survey). Page 1 HRP Staff Contact Information Education and Page 2 Reminders: Institutional Review Board ’A’ IRB Team ‘D’ [Biomedical] [Biomedical IRB Chair: Tahseen Mozaffar, MBBS Expedited and Exempt Submissions] Matt Kinder, CIP Jessica Sheldon, CIP 949-824-9819 Administrator Mihaela Nistor, CIP 949-824-3711 Senior Analyst Analyst There is no grace period extending the conduct of research beyond the expiration date of IRB approval. The study expires at midnight of the date specified on the approval letter and the informed consent document. If the IRB does not re-approve the research by the specified expiration date, study activities must cease (note: this includes access to identifiable data), pending re-approval of the research by the IRB. Once notified of the expiration, if the Investigator feels that stopping ongoing research-related interventions or interactions would jeopardize the rights or welfare of current subjects, the Investigator must immediately submit to the IRB Chair a list of research subjects for whom expiration of the research would cause harm. The Investigator may work with HRP Staff to facilitate the communication with the IRB Chair. The IRB Chair reviews this list and allows individual participants to continue participating in the research interventions or interactions only when the IRB determines that it is in their best interests. However any information collected during the lapse in approval may not be used for research. Remember: submit a continuing protocol application at least 30 days prior to expedited review and at least 60-90 days prior for full committee review. 949-824-3831 Le’Quan Jackson Joy Chu jessica.sheldon@uci.edu Senior Analyst mnistor@uci.edu Approval IRB Vice Chair: Ruth Mulnard, RN, DNSc Administrator mkinder@uci.edu Expiration of IRB 949-824-6662 ldjackso@uci.edu Michael Baird 949-824-6068 Analyst joy.chu@uci.edu 949-824-0665 ————————————————— ————————————————— Institutional Review Board ‘B’ Karen Allen, MA, CIP bairdm@uci.edu [Biomedical] Director IRB Chair: Kenneth Linden, MD, PhD Research Protections Cheree DuBose, CIP karen.allen@uci.edu Administrator 949-824-2576 cheree.dubose@rgs.uci.edu 949-824-1558 Beverley Williams, CIP Assistant Director Human Research Protections Open Position 949-824-5746 Senior Analyst beverley.williams@uci.edu Theresa Sanchez, CIP Debbie Melamud, MPH Analyst 949-824-2125 tmsanche@uci.edu —————————————————— Administrator Human Research Protections debbie.melamud@uci.edu Human Institutional Review Board ‘C’ Research [Social - Behavioral] Protections IRB Chair: Elizabeth Cauffman, PhD U.S. Mail: Valerie Sanchez, MA, CCRP Office of Research Administrator University of California, Irvine 949-824-4779 5171 California Ave., Suite 150 valerie.ms@uci.edu Irvine, CA 92697-7600 Melissa Camarena The Office is Open: Senior Analyst Monday—Friday 949-824-7114 8am—5pm mccamare@uci.edu Open Position Analyst General Email: IRB@research.uci.edu Web: http://www.research.uci.edu/ FALL 2013