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STATE UNIVERSITY POLICY MANUAL Approved 2/03
SUNY COLLEGE AT BROCKPORT POLICY MANUAL 1. Statement of Principles In addition, federal and state laws and regulations require these protections. In order for the College to fulfill its responsibilities and to comply with the law and regulations, all human participants research conducted under College auspices (including class projects) must receive appropriate review and approval. In our Federal Assurance on file with the Office for Human Research Protections (OHRP), U.S. Department of Health and Human Services, the College assures compliance with all requirements of Title 45, Part 46 of the Code of Federal Regulations (45 CFR 46) for all federally sponsored research, and all other human participants research, regardless of source of funding (if any). The College is guided by the ethical principles set forth in the Report of the National Commission for the Protection of Human Participants of Biomedical and Behavioral Research, entitled, Ethical Principles and Guidelines for the Protection of Human Subjects of Research (Belmont Report). Since the conduct of research with human beings may raise fundamental ethical and civil rights questions, no distinctions in the monitoring of research will be drawn between funded and non-funded research, or between research conducted by faculty, staff, students, other College personnel, or affiliated researchers. The policies in the document apply equally to all research involving human participants conducted under the auspices of SUNY College at Brockport. All faculty, staff, students and affiliated researchers who conduct or anticipate conducting research projects (either on or off campus) involving human participants are responsible for familiarizing themselves with and complying with these policies. 2. Definitions SUNY College at Brockport has adopted the definitions included in the Federal regulations for the protection of human participants in research (45 CFR 46.102). A. Department or Agency Head means the head of any Federal Department or Agency and any other officer or employee of any Department or Agency to whom authority has been delegated. B. Research means a systematic investigation (including research development, testing and evaluation) designed to contribute to general knowledge. Activities that meet this definition constitute "research" for purposes of this policy, whether or not they are conducted or supported under a program that is considered research for other purposes. For example, some "demonstration" and "service" programs may include research activities. C. Human participant means a living individual about whom an investigator
(whether faculty, staff or student) conducting research obtains: Intervention includes both physical procedures by which data
are gathered and manipulations of the participant or the participant's
environment that are performed for research purposes. Interaction includes
communication or interpersonal contact between investigator and participant.
Private information includes communication about behavior that occurs
in a context in which an individual can reasonably expect that no observation
or recording is taking place, and information which has been provided
for specific purposes by an individual and which the individual can D. Legally authorized representative means an individual or judicial or other body authorized under applicable law to consent on behalf of a prospective subject to the participant's participation in the procedure(s) involved in the research. E. Minimal risk means that 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 examinations or tests. 3. Institutional Responsibilities A. Scope of Responsibility
C. Protections for Vulnerable Populations D. Provision of Resources E. Education and Training G. Administrative Oversight 4. Responsibilities of the Institutional Review Board Administrator B. The Institutional Review Board Administrator shall receive from C. The Institutional Review Board Administrator shall forward certification of IRB approval of proposed research to the appropriate Federal department or agency only after all IRB required modifications have been incorporated to the satisfaction of the IRB. D. The Institutional Review Board Administrator will inform the IRB of
all E. The Institutional Review Board Administrator shall provide advice on the preparation of the Institutional Review Board review form and other documents, and other advice that will facilitate the IRB review process. F. The Institutional Review Board Administrator shall maintain and arrange
G. The Institutional Review Board Administrator is responsible for ensuring
H. The Institutional Review Board Administrator shall arrange for and
5. The Institutional Review Board (IRB) Review Process .A. Membership of the IRB b. The IRB will be sufficiently qualified through the experience and
c. The IRB will be able to ascertain the acceptability of proposed d. The IRB will include qualified persons of both sexes so long as no
e. The IRB will include at least one member whose primary concerns f. The IRB will include at least one member who is not otherwise g. No IRB member may participate in the IRB's initial or continuing h. The IRB may, at its discretion, invite individuals with competence
in b. The Provost or designee with input from the Institutional Review Board Administrator shall appoint the Chair of the IRB on an annual basis. 3. IRB Membership Lists and Qualifications b. All changes in IRB membership are reported to OHRP as appropriate. B. General Principles of IRB Review 1. It is the policy of the College that its IRB review all research involving human participants. The IRB has the responsibility and authority to review, approve, disapprove, or require changes in and monitor research activities involving human participants. No individual involved in the conduct and/or supervision of a specific project shall participate in IRB review, except to provide information. 2. In accordance with the compositional requirements of 45 CFR 46, the College has established an IRB. A list of members is in the attached appendix. 3. No involvement of human participants in research, including recruitment, is permitted until the IRB has reviewed and approved the research protocol, and informed consent has been obtained, unless waived in accordance with federal regulations. It is the responsibility of any investigator to obtain approval from the IRB prior to the initiation of any research, including pilot or pre-test studies involving the use of human participants. 4. All activities involving humans as research participants must provide for the safety, health, and welfare of every individual. Rights, including the right to privacy, must not be infringed. No participant in a research activity shall be exposed to unreasonable risk to health or well-being. 5. An individual does not abdicate any rights by consenting to be a research participant. A participant has the right to withdraw from a research project at any time or can refuse to participate without loss of benefits to which the subject would otherwise be entitled. Further, a participant has the right to receive appropriate professional care, to enjoy privacy and confidentiality in the use of personal information, and to be free from undue embarrassment, discomfort, anxiety, and harassment. 6. The direct or potential benefits to the participant, or the importance of the knowledge to be gained, must not preclude consideration of the inherent risks to the individual. 7. The confidentiality of information received from participants in experiments or respondents to questionnaires or surveys shall be fully protected, both during and after the conduct of a research activity, within the limits of the law. 8. Participation in projects must be voluntary. Informed consent must be obtained from all participants and must be documented (unless the requirements for documentation of consent is specifically waived by the IRB). Methods in accordance with the requirements of 45 CFR 45.116 and 45.117, appropriate to the risks of the research, must be used to obtain the participants' informed consent. 9. In research involving more than minimal risk or substantial stress or discomfort, such risk, stress, or discomfort shall be carefully explained to the participant before his or her participation and justified by the expected benefits of the research. The investigator shall be satisfied that the explanation has been understood by the participants, and the written consent of the participant (unless otherwise waived by the IRB), containing the substance of the explanation, shall be obtained and kept as a matter of record. C. IRB Responsibilities 1. The IRB shall follow the written policies and procedures of the College for the protection of human participants in research. These policies and procedures are in compliance with Federal regulations and State law. 2. Except when an expedited review procedure is applicable, the IRB shall review proposed research at convened meetings at which a majority of the members are present, including at least one member whose primary concerns are in non-scientific areas. In order for the research to be approved, it will receive the approval of a majority of those members present at the meeting. 3. The IRB will review and have the authority to approve, require modifications
in (to secure approval), or disapprove all research activities, including
changes in previously approved human participants research. 5. The IRB will require documentation of informed consent or may waive documentation in accordance with 45 CFR 46.117. 6. The IRB, through the IRB Administrator, shall notify 7. Certification of IRB review and approval for all Federally-sponsored research involving human participants will be submitted to the IRB Administrator for forwarding to the appropriate Federal department or agency. Compliance will occur within the time and manner prescribed for forwarding certifications or IRB review to DHHS or other Federal department(s) or agency. 8. The IRB Administrator will designate procedures for the retention
of SUNY College at Brockport IRB records and documents for six years after
completion of the research activity in compliance with New York State
and Federal regulations. D. Scope of Review IRB review and approval is required for any research involving human E. Levels of Review
While the investigator shall make the initial determination regarding
the 1. Exempt review a. To qualify for exempt review, a research activity must present no
possible risk to subjects 18 years of age and older and be one of the
following activities:
The research is exempt from the requirements of informed consent
b. The expedited review is carried out by the IRB Chair and one 3. Full Committee Review a. All proposed research deemed by the IRB to present more than minimal risk to human participants must be reviewed by the IRB. b. Examples of research activities that must be reviewed by the full IRB committee include:
c. Attendance of the investigator (and their faculty supervisor if appropriate) at the IRB review meeting at which their research activity is discussed is strongly encouraged. d. The IRB will come to one of three determinations regarding an application:
e. All IRB Category 3 initial review and continuing review protocols shall be distributed to all members of the IRB prior to the meeting for proposals with faculty/staff/graduate students. For undergraduate student class projects (only) a review will require only three IRB members for review at a category 3 meeting. f. When it is determined that consultants or experts will be required to advise the IRB in its review of a protocol, the research protocol will also be distributed to the consultants or experts prior to the meeting. g. A majority of the membership of the IRB constitutes a quorum and is required in order to convene a meeting for the review of research protocols. h. An IRB member whose concerns are primarily in non-scientific areas must be present at the convened meeting before the IRB can conduct its review of research. i. For a research protocol to be approved, it must receive the approval of the majority of those voting members present at the convened meeting. j. Approval of the proposed research is usually granted for a period of 12 months commencing on the date the approval is granted by the IRB. Based upon the degree of risk to human participants, the IRB may grant special conditions whereby the investigator has a shorter approval period or must report research progress at specific intervals. Continuation of projects past the approval period require project continuation review and approval by the IRB. k. Investigators will be notified in writing of the IRB's decisions l. When the research activity involves an outside agency (e.g.hospital, public school, etc.), the investigator must secure written approval on agency letterhead from an appropriate official within the agency prior to conducting the research. This should be submitted with the IRB proposal. If it is not, final approval will be delayed until it is submitted to the IRB Administrator. m. The IRB may not have a member participating in the IRB's initial or
continuing review of any project in which the member has a conflicting
interest, except to provide information requested by the IRB. 1. Risk/Benefit - in order to approve research covered by this
b. Risks to participants are reasonable in relation to anticipated benefits, if any, to participants, and the importance of the knowledge that may reasonably be expected to result from the research. c. In evaluating risks and benefits the IRB will consider only those risks and benefits that may result from the research (as distinguished from risks and benefits that may result from therapies participants would receive even if not participating in the research). The IRB will not consider long-range effects of applying knowledge gained in the research (for example, the possible effects of the research on public policy) as among those research risks that fall within the purview of its responsibility. The IRB will examine study design or scientific merit of a proposed study within the context of its risk/benefit analysis. 2. Equitability of Participant Selection and Recruitment - The IRB shall ensure that the recruitment of participants is equitable and free of coercion. 3. Informed Consent Process - Informed consent will be sought from each prospective participant or the participant's legally authorized representative and will be appropriately documented. In accordance with and to the extent required by 45 CFR 46.116 and 46.117. 4. Privacy and Confidentiality - The IRB shall determine that adequate provision has been taken to protect the privacy of participants and for ensuring the confidentiality of an individual's participation and confidentiality of study data, as appropriate. 5. Special Populations - when some or all of the participants are likely to be vulnerable to coercion or undue influence (such as children, prisoners, pregnant women, physically or mentally disabled persons, or educationally or economically disadvantaged persons), additional safeguards must be included in the study to protect the rights and welfare of these participants. 6. Review by College - Research covered by this policy that has been approved by the IRB may be subject to further appropriate review and approval or disapproval by officials of the College. However, College officials may not approve the research if it has not been approved by the IRB (CRF 46.112). 7. Monitoring of data - When appropriate, the research plan shall include adequate provision for monitoring the data collected to ensure the safety of participants. G. Suspension or Termination of IRB Approval of Research 1. The IRB has the authority to suspend or terminate approval of 2. Any suspension or termination of approval shall include a H. Continuing Review 1. The IRB is required to reevaluate research projects at intervals 2. For research with a one-year approval period, investigators must request a continuation for the approval yearly if the activity lasts more than one year. Only two continuations will be granted for a given project. After three years, the project must be resubmitted, as a new protocol to the IRB for review and approval. I. Modifications All modifications to currently approved research are required to have IRB review and approval prior to implementation. Minor changes that do not increase the risk to research participants may receive an expedited review. Modifications to approved research projects that may affect the risk to participants are forwarded to the IRB for full review. J. Reviewing Reports of Adverse Events 1. The IRB is responsible for reviewing reports of any adverse events to research participants or any unanticipated problems that involve risk to human participants in the course of approved research. 2. Upon the receipt of an adverse event, the IRB will determine whether the study should be modified to reduce the level of risk to participants, or whether the consent form should be modified to include a description of activities or procedures that could result in adverse effects. 3. Site visits for specific projects made be made by the IRB Chair and Administrator and possibly IRB Board members only "for cause." Cause is defined as reporting of an adverse event. Additional oversight of projects may be required on a case-by-case basis. K. IRB Policy Regarding Research Conducted Without IRB Approval
2. A letter from the IRB Administrator will be sent to the investigator indicating the reasons for the IRB's decision, what actions the IRB is requiring, and an opportunity to respond to the Board. A copy of the letter will be sent to the faculty advisor if the investigator is a student. L. Research Lacking Definite Plans for the Involvement of As provided for under 45 CFR 46.118, applications and proposals lacking
definite plans for involvement of human participants will not require
IRB review and approval prior to external funding. However, except for
research exempt or waived under 45 CFR 46.110(b), human participants may
not be involved in any project supported by such awards until IRB M. Research Undertaken Without the Intention of Involving As required under 45 CFR 46.119, the IRB will review proposed involvement of human participants in Federal research activities undertaken without prior intent for such involvement, but will not permit human participants involvement until certification of the IRB's review and approval is received by the appropriate Federal department or agency. N. IRB Records 1. The IRB Administrator with secretarial assistance shall prepare and
maintain adequate documentation of IRB activities, in accordance with
45 CFR 46.115, including the following: b. Minutes of IRB meetings which shall be of sufficient detail to show attendance at the meetings; actions taken by the IRB; the votes on these actions including the number of members voting for, against, and abstaining; the basis for requiring changes in or disapproving research; and a written summary of the discussion of controversial issues and their resolution. c. Records of continuing review activities. d. Copies of all correspondence between the IRB and investigators. e. A list of IRB members in the same detail as described in 45 CFR 46.103(b). f. Written procedures for the IRB in the same details as described in 45 CFR 46.103(b)(4) and (5). g. Statement of significant new findings provided to participants as required by 45 CFR 46.116(b)(5). 2. The records required by this policy shall be retained for at least
six years, and the records related to research that was conducted shall
be retained for at least six years after the completion of the research.
These records must be appropriately secured. All records shall be accessible
for O. Appealing an IRB Decision 1. If the IRB makes a decision that an investigator believes to be unfair, unsubstantiated, or unduly restrictive on his/her proposed research, the investigator should first discuss the matter with the Chair of the IRB and the IRB Administrator. The investigator should be prepared to present reasons that he/she believes that the proposed research is in compliance with College policy and Federal regulations for the protection of human participants. 2. If the issue cannot be resolved satisfactorily by negotiation, the investigator may appeal the decision, in writing, to the IRB. 3. In developing their appeal, the investigator is encouraged to seek the advice or opinion of an objective, qualified consultant (or consultants) to support the claim that the proposed research is in compliance with human participants policy and regulations. 4. The investigator must appear before the IRB to present their appeal and any supportive material or documentation obtained through consultation. Based upon this appeal, the IRB will issue a final recommendation on the proposed research.
In accordance with the provisions of the College's Federal Assurance
Filing research investigators who conduct human participants research
under the auspices of the College (faculty, staff, students and affiliated
researchers), acknowledge and accept their responsibility for protecting
the rights and welfare of human research participants and the following: Safeguarding the well being of and information about an individual is
a B. Preparation of Human Participants Review Form
C. Submission of the Human Participants Review Form It is the responsibility of each investigator to bring all proposed research activity involving the use of human participants or activity involving data collection from or about human participants to the attention of the College for review and approval. It may not be readily clear if a proposed research project involves human participants. The investigator is strongly encouraged to consult the IRB Administrator on the question. Final authority for making the determination on whether the research is human participant research rests with the IRB. D. Reporting Modifications in the Research
E. Submission of Requests to Continue Research F. Apprising Research Participants of Findings That May Affect
G. Complying With IRB Decisions H. Providing Consent Forms to All Participants Research investigators are responsible for retaining the informed consent Investigators are responsible for immediately reporting to the IRB any K. Attending IRB Meetings Research investigators are strongly encouraged to attend IRB meetings
in L. Education and Training Prior to the submission of an IRB application for IRB review, the M. Cooperative Research Investigators must fully apprise the IRB of research activities at any collaborating site(s). Any change in a previously approved protocol regarding these activities must be submitted and approved by the IRB as a modification before being implemented. 7. Cooperative Research A. SUNY College at Brockport will ensure that any of its collaborating entities(i.e. those engaged in human participant research by virtue of subject accrual, transfer of identifiable information, and/or in exchange for something of value, such as material support, co-authorship, intellectual property, or credits) materially engaged in the conduct of non-federally sponsored research involving human subjects will possess mechanisms to protect human subjects that are at least equivalent to those procedures provided for in the ethical principles to which the College is committed. B. The College will comply with the requirements set forth in 45 CFR 46.114 regarding cooperative research projects. C. The College may enter into a joint review arrangement, rely upon the review of another qualified IRB that adheres to similar standards of human participant protection, or make similar arrangements for the purpose of meeting the IRB review requirements and obviating duplication of effort. Such arrangements must be: a) in writing, b) approved and signed by the IRB Administrator, c) signed by the correlative officials of each of the cooperating institutions. These arrangements may be entered into on a case-by-case basis if arrangement is needed for the review of a single research project. Or, for ongoing cooperative research, a more formal arrangement may be entered into - e.g., a memorandum of understanding detailing the joint review mechanism(s). D. SUNY College at Brockport research studies involving a collaborating
8. Education and Training A. The Provost and/or the Dean of Graduate Studies, the IRB Chair, the IRB Administrator, and IRB members must successfully complete the required CITI training program. Additionally, IRB members will be required to participate in ongoing educational and training programs as identified. New IRB members must complete an orientation program to the IRB process offered by the IRB Administrator. B. Prior to the submission of human participants review forms for IRB review, the investigator and all key personnel listed on the application must successfully complete the College required CITI training program. If the investigator is a student, their faculty advisor must also complete the CITI training program. 9. Appendices These policies were unanimously approved by the IRB 2/03 and minor modifications made 8/06 (new web site address and roster of members).
1. Jan Gillespie, Chair
3. Jennifer Boyle 4. John Chelonis 5. Jason Dauenhauer 6. Kathy Goetz 7. Tom Hernandez 8. Justin Laird 9. Sue Novinger 10. Deanna Shifton 11. Christopher Williams Marsha Moss, Administrative Assistant
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© 2003-2008 State University of New York College at Brockport
The College at Brockport * 350 New Campus Drive * Brockport, NY 14420