Human Research Protections News Brief SUMMER 2010 Inside this issue: All About the IRB Approval 1-3 Letter Chair of Here’s the scenario: You have just been notified that your new human subject research study has been approved by the IRB. This notification comes via email with a link to the webbased IRB “Document Depot.” You access your IRB-approved, stamped Consent Form and Protocol Narrative, along with the HIPAA Research Authorization Form you previously submitted. Additionally, you find the IRB approval letter in the “Docs” Depot. You think to yourself, “I don’t need to read the approval letter—it’s standard jargon and besides, the study is approved! I’ll just save it to my desktop or file it away for recordkeeping purposes.” While it may be common practice to simply file away the IRB approval letter without reviewing it, in reality, it’s a bad idea. The IRB approval letter lists the committee’s determinations regarding your approved human research study. It provides information about the informed consent process and HIPAA Authorization requirements and includes helpful reminders. Meet Dr. Linden, ALL ABOUT THE IRB APPROVAL LETTER So, lets go over a few of the important sections of the IRB Approval letter: 4 IRB “B” First Paragraph of the Approval Letter: Researchers are only approved to conduct the research as described in the IRB-approved Protocol Narrative. IRB Staff Contact The IRB’s determinations begin at the bottom of the first page. Info Level of Review, Approval Period and the FWA: & Education Items and Reminders 5 The level of review: Expedited (research involving no more than minimal risk) or Full Committee (research involving greater than minimal risk), the approval date and the expiration date is listed on the bottom of the letter. In addition, UCI’s Federalwide Assurance (FWA) number is included. The Federal Policy (Common Rule) for the protection of human subjects requires that each institution "engaged" in Federally-supported human subject research file an Assurance with the Office of Human Research Protections. The assurance formalizes the institution's commitment to protect human subjects. Page 2 IRB Determinations as Conditions of Approval: If vulnerable populations, such as children, pregnant women, and/or prisoners are to be enrolled in the research, the approval letter will include the applicable IRB determinations. When enrolling children and pregnant women, the letter will also explain who must provide informed consent. For example, when enrolling children in research that involves greater than minimal risk where the research presents potential benefit to the subjects, the IRB may determine that one parent’s or legal guardian’s signature is sufficient to obtain parental permission rather than requiring permission from both parents. This information is included in the IRB approval letter. If an investigational drug is being studied the approval letter will indicate whether an IND is on file or that an IND is not required. If an investigational medical device is involved the letter will list the IRB’s device determination—Exempt, Non-Significant Risk (NSR) or Significant Risk (SR). If the use of a placebo was approved this too would be reflected on the IRB approval letter. Informed Consent Determinations: The informed consent requirements as determined by the IRB are included in the above reflected section of the approval letter. Are subjects required to document their informed consent by signing a consent form or has a waiver of signed consent been granted? Is child assent required? Is HIPAA Research Authorization required from subjects or was a waiver granted? It is critical that researchers review the IRB Approval letter and understand the IRB determinations. If you are unsure what is required, please contact the HRP Staff for assistance. SUMMER 2010 Page 3 Approval Conditions For All UCI Human Research Protocols: In addition to the IRB determinations specific to the approved research, we highly recommend that researchers periodically review the additional conditions and required clearances section on the last page of the IRB approval letter as reflected below. SUMMER 2010 Meet Dr. Linden– Chair of IRB “B” Page 4 Kenneth Linden, M.D., Ph.D. is an Associate Professor in the Department of Dermatology at UC Irvine Medical Center. Dr. Linden is a melanoma expert with UC Irvine Healthcare’s Melanoma Center in the Chao Family Comprehensive Cancer Center. He also practices general and surgical dermatology at Gottschalk Medical Plaza on the UC Irvine campus. He is a diplomat of the American Board of Dermatology and a fellow of the American Academy of Dermatology. How were you appointed as the IRB B Chair? I was serving as a member on the IRB when the Vice Chair, Bill Armstrong, left to become the interim chair of ENT. Much to my surprise, I was asked if I would become the Vice Chair – I don’t know what they were thinking. I was then happy in the role of Vice Chair under the excellent Chair, Bob Burger. When a career advancement for Dr. Burger caused him to leave UCI, I was asked to serve as the Chair. I felt it was my duty and challenge to try to lead the IRB to the high standards he had set. What is your expertise as it relates to the protection of human research subjects? Dr. Linden currently I have conducted my own human subjects research as principal investigator and been involved as a co- serves as the Chairman for IRB “B” investigator on numerous clinical trials. I am currently the lead researcher on a multicenter human subjects clinical trial related to the treatment of melanoma. Being on the IRB as a member, and then as Vice-Chair, I learned a lot by participating in the IRB meetings and review process. By working with the highly knowledgeable Human Research Protections (HRP) staff as Chair, I have learned a great deal more about human subjects protection, particularly the regulatory aspects. Do you have any advice for new researchers at UCI? My advice is, if you have any comments, questions, concerns, or complaints, call HRP staff, not me ... (actually, just joking about the not me part). They are here to help you. HRP staff and the IRB are here to help facilitate research. We need your feedback, both positive and negative, to continue to improve the program as well as to ensure that researchers have the education and other resources they need to carry out human subject research projects at UCI. As an IRB Chair, how much time is spent on IRB activities in any given month? About 12-15 hours a month, sometimes more – actually seems like more lately. What is the hardest part of being an IRB Chair? Finding a balance between protecting human research subjects but at the same time being facilitative to UCI researchers. What is the most rewarding part of being an IRB Chair? The most rewarding part of being an IRB chair is when the actions of the IRB actually lead to an important increase in human subjects safety. In addition, it is rewarding when a particularly satisfying combination of protecting human research subjects and helping to further important biomedical research at UCI can be achieved. Working with HRP staff is also quite rewarding. Is there anything you want the UCI Researchers to know about the IRB? The IRB and HRP staff welcomes all communication with the UCI research community. Come and serve on the IRB — you will have a better understanding of the charge of the IRB as well as an appreciation for all that is involved in the review process. My experience is that nearly all researchers have a somewhat negative view of the IRB until they serve on it, but once they serve on it, they find the reviews of the research that is going on at UCI so interesting and rewarding that they usually end up volunteering for a second term or further once their term is up. Is there anything else you would like to add? I am continually impressed with the professionalism, commitment, and conscientiousness, of the IRB members and the HRP staff. The HRP staff in particular are outstanding in their knowledge of human subjects protection and are all a great deal of fun to work with. SUMMER 2010 HRP Staff Contact Information IRB Team “D” Biomedical Expedited and Exempt Submissions Institutional Review Board “A” Biomedical —————————————————Matt Kinder Administrator 949-824-9819 mkinder@uci.edu ——————————————————— Laverne Estanol Administrator 949-824-3831 lestanol@uci.edu Debbie Gonzalez Analyst 949-824-3711 Kristina Grimaldi Analyst 949-824-5057 Kristina.grimaldi@research.uci.edu Debbie.gonzalez@research.uci.edu Timothy Grigsby Assistant 949-824-6068 Tim.grigsby@research.uci.edu ————————————————— Institutional Review Board “B” Biomedical Cheree DuBose Analyst 949-824-5622 cheree.dubose@research.uci.edu —————————————————— Institutional Review Board “C” Social - Behavioral Jessica Sheldon Administrator 949-824-4779 jessica.sheldon@uci.edu Alicia Asgari Analyst 949-824-7114 ateiman@uci.edu Matthew Alcala Assistant 949-824-6662 Matthew.alcala@research.uci.edu Kin Hang Assistant 949-824-0665 kkhang@uci.edu ————————————————— Education & Reminders: Don’t forget to open, review and save all of your latest, IRBapproved documents which can be found in the IRB Document Depot @ http:// apps.research.uci.edu/irbdocs/. Please make sure to save your submission as well as the IRB approved, stamped versions as part of your record-keeping responsibilities. These documents may be stored electronically or in hard copy. Karen Allen Director Human Research Protections 949-824-1558 kallen@uci.edu Valerie Sanchez Administrator 949-824-7109 vmiran@uci.edu Theresa Sanchez Assistant 949-824-2125 tmsanche@uci.edu Page 5 Beverley Esparza Assistant Director Human Research Protections 949-824-5746 besparza@uci.edu Remember, only the LATEST versions will be maintained in the Human Research Protections U.S. Mail: Office of Research Administration University of California, Irvine 300 University Tower Irvine, CA 92697-7600 The Office is Open: Monday—Friday 8am—5pm Document Depot. Once a modification request or continuing application is approved, the previously IRBapproved documents are removed from the Document Depot. Use the working draft versions available on the Document Depot when submitting modification requests and continuing We’re on the Web! http://www.research.uci.edu/ora/ hrpp/index.htm review applications. Submission of incorrect versions will delay review and approval. SUMMER 2010