VOLUME 1 ISSUE 3 FEBRUARY, 2007 New IRB Application Forms The Institutional Review Board (IRB) has jurisdiction over all human subjects research that involves any form of social/behavioral/educational research to include both experimentation and investigation (e.g., research involving paper or on-line questionnaires, surveys, interviews, focus groups, etc). Additionally, the IRB has jurisdiction over participation of human subjects in any type of biomedical/clinical research. As IRBs are sensitive to specific aspects of both biomedical and social/behavioral/educational research in their review of protocols, new IRB project application forms have been implemented. The IRB has created two separate IRB application forms specific to biomedical research and social/behavioral/educational research. These new forms are available online at: http://www.southalabama.edu/com/research/humansubjects/irb.shtml The IRB will continue to update these application forms as a way to improve the clarity of the questions asked and the format for providing information to the IRB for review. Keep in mind that providing well-organized and concise application forms are likely to assist IRB staff and board members conduct a comprehensive review and assess the criteria necessary for facilitating IRB approval in a timely fashion. As a reminder, federal regulations exempt some types of research involving human subjects from the normal review process of the IRB. The IRB requires exempt research to be completed on the “IRB Request for Exemption Review” form and will be adminstratively reviewed to determine if exemption status is warranted. Exempt activities include those that present no more than minimal risk to subjects which are defined as “the probability and magnitude of harm or discomfort anticipated in the research are not greater in and of themselves than those ordinarily encountered in daily life or during the performance of routine physical or psychological examination or test”. The research study must fall into one of the six categories in the regulations’ list of procedures that qualify for an expedited review process. The use of vulnerable subjects such as minors, prisoners or pregnant women in the study automatically exclude the research from exempt status. Inside This Issue PAGE Human Subjects: New IRB application forms 1 Regulatory Binder Documents 2 Closure of study protocol 2 Biosafety Report: 2006 Inspection Findings Animal Care and Use: NIH Policy on Allowable Costs for Grant Activities ILAR online journal Contact us at: CSAB 128 251-460-6625 (Office) dlayton@usouthal.edu -1- 3 3 Articles on Research Ethics: 4 Office of Research Compliance Research activities involving human subjects that are exempt from IRB review are identified in 45CFR 46.101(b)(1)-(6). This information is available on the Office of Human Research Protections website at: http://www.hhs.gov/ohrp/humansubjects/guidance/45cfr46.htm#46.101 3 Regulatory Binder Documents Principal Investigators conducting research with human subjects need to maintain a regulatory binder for their IRB approved protocols. The regulatory binder helps to effectively organize the study documents as are required by federal regulations and good clinical practices. Information to be included in the binder (where applicable): 1. Monitoring log (sponsor audits) and subject enrollment log 2. Training certificates: Human subjects, HIPAA in Research (when adding personnel to the study, they must complete the required training prior to participating in the study) 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. CVs/COIs/FDA 1572 Copies of all IRB approvals (initial, renewal, amendments) Informed consent (all IRB approved versions) Copy of the IRB protocol application form Copies of any advertisement(s) and IRB approval Copies of all IRB related correspondence Protocol and Investigator’s Brochure Protocol violations/deviations Adverse Events Lab certificates for studies utilizing laboratories for specimen testing 13. Statement of Regulatory Compliance: Contact the Office of Research Compliance and Assurance for additional assistance in the preparation of regulatory documents Label the binder with the protocol number, Investigator name and study site http://www.southalabama.edu/com/research/pdf/compliancestatement04.pdf 14. Copy of grant application, if applicable Remember, investigators must retain signed consent forms, assent forms for all research subjects for a minimum of three years after study closure. These forms should be maintained in a secure location and separate from the data for the study. When to Close Out a Study Protocol Suggestions for newsletter improvements or contributions are welcomed – please email the Office of Research Compliance and Assurance: dlayton@usouthal.edu Study closure is defined as the termination of the conduct of the study. This does not include a study that is no longer accruing subjects, as those studies may still follow subjects and receive incentives. As a general rule of thumb, you should submit a final report form when: enrollment of subjects is closed, and data collection is complete, and there is no additional research beyond the original use of the data The federal definition of research involving human subjects includes analysis of data or secondary use of the data if they still contain individually identifying information. -2- 2006 Biosafety Inspection Findings The Institutional Biosafety Committee (IBC) carries out annual biosafety inspections during the month of December. These inspections are directed at ensuring our research laboratories employ appropriate safety precautions and containment to protect our employees and the environment from potential risk emerging from those procedures involving genetically modified or pathogenic organisms. As of the 2006 calendar year, 47 labs totaling 136 active biohazardous and/or recombinant DNA registrations were inspected. There were no major shortcomings noted during the inspections. However, there were concerns to be addressed in one facility involving equipment performance and facilities control systems. Nineteen or 40% of labs attained full compliance as compared to 38% in year 2005. Overall, the inspection process indicated that research involving biohazarouds materials are being performed in accordance with required safety precautions and procedures. NIH Policy on Allowable Costs for Grant Activities Involving Animals when Terms and Conditions are not Upheld “A new notice, entitled Guidance Addressing the NIH Policy on Allowable Costs for Grant Activities Involving Animals when Terms and Conditions are Not Upheld, has been published in the NIH Guide for Grants and Contracts on January 26, 2007 as Notice Number NOT-OD-07-044. This is a joint Notice from the Office of Policy for Extramural Research Administration (OPERA) and Office of Laboratory Animal Welfare (OLAW). The NIH Guide for Grants and Contracts is the official publication for NIH medical and behavioral research grant policies,ofguidelines funding opportunities”. The August notice 2006 can be accessed at: Source Information:and Report on Research Compliance, http://grants.nih.gov/grants/guide/notice-files/NOT-OD-07-044.html Source: NIH, Office of Laboratory Animal Welfare Institute for Laboratory Animal Care Research (ILAR) Journal Online ILAR is published quarterly by the Institute for Laboratory Animal Care Research, National Council and are peer-reviewed and approved by the Editorial board before publication. ILAR e-Journal is an electronic companion to the print journal that provides information for the scientific community, IACUCs and veterinarians through publishing topics devoted to animal research. In order to access the ILAR e-Journal, you must use an USA IP address (e.g., campus PC), as our subcription is linked to the insitution. The online web address is: www.national-academies.org/ilar The ILAR recently published an article entitled, “Verification of IACUC Approval and the Just-in-Time Process. The article can be assessed at: http://dels.nas.edu/ilar_n/ilarjournal/instpdf/47_2_E-1_2006_Mann.pdf -3- Articles on Research Ethics “Leading By Example”, Nature 445, 229 (18 January 2007) The primary safeguard against scientific misconduct is the example set every day by thousands of senior researchers in the laboratory. “Breeding Cheats”, Nature 445, 242-243 (18 January 2007) Understanding the social and psychological factors behind scientific misconduct will enable bad practice to be minimized, but never eliminated, says Jim Giles. Academic Medicine, Journal of the Association of American Medical Colleges, January 2007, Volume 82, Issue 1. The edition has several articles related to research ethics. Learn more at http://www.academicmedicine.org/pt/re/acmed/currenttoc.htm;jsessionid=FrzTtwM5h4nyghgt0mfHNrtXQMLnGZYYRt1y RPpvL5vZnJJwlnWx!2118075020!-949856145!8091!-1 “House Challenges Bush on Stem Cells, Again”, Jeffrey Brainard, The Chronicle of Higher Education, January 12, 2007. The U.S. House of Representatives re-approved a bill to expand federal spending for research on human embryonic stem cells, but not by a large enough margin to overturn an expected veto by President Bush. Learn more at http://chronicle.com/daily/2007/01/2007011202n.htm. Newsletter archives are available through the Office of Research Compliance website at: http://www.southalabama.edu/com/research/ -4-