REVIEW OF RESEARCH

401  Research Exemption from IRB Review.. 2

402  Expedited Review.. 7

403  Initial Review – Criteria for IRB Approval 15

404  Continuing Review.. 22

405  Amendments. 31

406  Adverse Events

407  Unanticipated Problems & Protocol Deviations. 35

408  Study Completion. 39

409  Categories of Action. 43

410  Study Recruitment & Advertisements. 48

 

 

 

 


 

SOP: 401

Version No: 1

Effective Date: 07/01/2005

research exempt from

irb review

Supercedes Document Dated: 10/15/04

 1.  POLICY

All research involving the collection of data, through intervention or interaction, with living individuals or human tissues, will be reviewed by the IRB.  An Investigator is NOT empowered with the ability to make the determination of whether a research project is exempt from IRB review.  It is the Investigator’s responsibility to forward any human participant research project to the IRB and it is the IRB’s responsibility to determine if the research project is exempt from review.  The IRB Chairperson or Vice-Chairperson makes the determination of exemption based on regulatory and institutional criteria except as specifically noted below.

When a research project is reviewed under exempt criteria, the review takes into consideration the level of risk involved as well as ethical concerns that may pose potential harm to a participant.  If the reviewer finds that the ethical issues pose more than a minimal risk to the participant but the type of research falls within the exempt criteria, it is at the discretion of the IRB Chairperson to determine that the project will be reviewed as either expedited or by the convened IRB.

 

Specific Policies

1.1  Exempt Research Project Criteria

Research projects in which the only involvement of human participants will be in one or more of the following categories are exempt from IRB review under the following conditions:

1.1.1         Research conducted in established or commonly accepted educational settings, involving normal educational practices, such as:

a.         Research on regular and special education instructional strategies,

b.         Research on the effectiveness of or the comparison among instructional techniques, curricula, or classroom management methods.

Norman Campus IRB Note: Classroom evaluation activities do not require submission of an application to the IRB when assessment involves regular classroom activities and results of the evaluation process are intended to be used for the sole purpose of informing teaching practices of the instructor.

1.1.2         Research involving the use of educational tests (cognitive, diagnostic, aptitude, achievement), survey procedures, interview procedures or observation of public behavior, unless:

a.         Information obtained is recorded in such a manner that human subjects can be identified, directly or through identifiers linked to the subjects; and

b.         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.

1.1.3.        Research involving the use of educational tests (cognitive, diagnostic, aptitude, achievement), survey procedures, interview procedures, or observation of public behavior that is not exempt, if:

a.         The human subjects are elected or appointed public officials or candidates for public office; or

b.         Federal statute(s) require(s) without exception that the confidentiality of the personally identifiable information will be maintained throughout the research and thereafter.

Norman Campus IRB Note: Research activities that are requirements of a course and are being conducted for the purpose of learning research skills only are not required to be submitted to the IRB for review except under the following conditions:

·        The research involves greater than minimal risk,

·        The research is conducted with the intention to publish or disseminate results (i.e. thesis or dissertation),

·        Participants are members of a vulnerable population (see SOP 501), 

·        The study will solicit sensitive information, unless results are reported anonymously, or

·        Any disclosure of participants' responses could reasonably place participants at risk of criminal or civil liability or be damaging to the participants' financial standing, employability, or reputation.

1.1.4.        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 participants.

                  Norman Campus IRB Note:

·        Research involving the use of publicly available existing data that does not include personal identifiers does not require submission of an application to the IRB.

·        Behavioral research 

 

1.1.5.        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:

a.         Public benefit or service programs;

b.         Procedures for obtaining benefits or services under those programs;

c.         Possible changes in or alternatives to those programs or procedures; or

d.         Possible changes in methods or levels of payment for benefits or services under those programs.

1.1.6.        Taste and food quality evaluation and consumer acceptance studies:

a.         If wholesome foods without additives are consumed, or

b.         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 FDA or approved by the Environmental Protection Agency or the Food Safety and Inspection Service of the U.S. Department of Agriculture.

1.2             Exempt Research Project Review

The IRB Chairperson, Vice-Chairperson, or IRB member designee will review research projects meeting exempt criteria; these projects will not require convened IRB review.  The IRB Chairperson or Vice-Chairperson will document the appropriate exempt criteria in the file folder.  Written documentation indicating the project meets exempt criteria and that the research may begin will be sent to the investigator.

 

 

1.3       Exempt Research Annual Verification

 

The status of research projects that originally qualified for exempt status will be determined on an annual basis.  The IRB will send a letter to the Investigator to determine if the research project remains active and continues to meet the qualifications for exempt status.

 

 

 

2.  SCOPE

These policies and procedures apply to Investigator claims for exemption from IRB review.

3.  RESPONSIBILITY

IRB Chairperson, IRB Vice-Chairperson, or IRB member designee is responsible for the review and determination of exempt research projects.

4.  APPLICABLE REGULATIONS AND GUIDELINES

45 CFR 46.101

21 CFR 56. 104, 105

5.  REFERENCES TO OTHER APPLICABLE SOPs

This SOP affects all other SOPs.

6.  ATTACHMENTS

401-A    Exempt Criteria List

401-A-1 Claim of Exemption Checklist for Staff

7.  PROCESS OVERVIEW

7.1             Exempt Review / Determination Procedure

Research projects that claim exempt status will be reviewed by the IRB Education Coordinator to confirm that Investigator has completed HRPP education requirements and forwarded to the IRB Coordinator.

The IRB Coordinator provides to the IRB Chairperson or designee the item for review as follows:

7.1.1   Upon initial review of the research project, the IRB Chairperson may request verification and/or additional Information from the Investigator in order to determine exemption.  This request will be communicated to the Investigator in writing. 

7.1.2   If the research project meets exempt criteria 1-6 as stated in Section 1.1 of this policy, the IRB Chairperson will stamp it approved, indicate the exempt criteria number, then forward the research project to the IRB Coordinator.

7.1.3       If the research project fails to meet the criteria for exemption, the IRB Chairperson will determine that the project requires approval under expedited criteria as referenced in SOP 402 or requires convened IRB review.

7.1.4       The IRB Coordinator is responsible for recording the date of the exempt determination in the database, generating an anniversary date for renewal, generating the approval letter, and forwarding the letter to the Investigator.

 

7.2                         Renewal of Exemption Procedure

The IRB will send a letter to the Investigator on an annual basis to determine if the research project remains active and continues to meet the qualifications for exempt status. 

 

 

7.2.1                   Within eleven months from the original approval date, the IRB staff will generate a notification letter to the Investigator.

7.2.2                   The Investigator must respond to the IRB noting if the project remains active and if changes have occurred that could change the qualifications for exempt status.

7.2.3                   If the Investigator does not respond by the anniversary date of the original approval, the IRB Coordinator will present the file to the IRB Chairperson for inactivation.

7.2.4                   The IRB Coordinator is responsible for recording the date of inactivation in the database, generating the inactivation letter, and forwarding the letter to the Investigator.

 

8.  PROCEDURES EMPLOYED TO IMPLEMENT THIS POLICY

Who

Task

Tool

IRB Assistant

 

Receives submission, conducts preliminary data entry, assigns the appropriate board, and forwards to IRB Coordinator for processing.

IRB Database

IRB Coordinator

Reviews submission for completeness, forwards to IRB Chairperson for review.

 

IRB Chairperson

Reviews application of the research project, provide stamp of approval and signature and route to IRB Coordinator for processing.  

 

Exempt Criteria List

IRB Education Coordinator

IRB Coordinator

Confirms Investigator has completed HRPP training requirements.

Generates the approval letter and presents to the IRB Chairperson for signature.  Makes  a copy of the signed approval letter and transmits to Investigator.  Files copy in the IRB file.

 

 


 

SOP: 402

Version No: 1

Effective Date: 07/01/2005

Expedited Review

Supercedes Document Dated: 10/15/04

 1.  POLICY

The categories of research that may be reviewed by the IRB Chairperson or designee through an expedited review procedure include research activities that (1) present no more than minimal risk to human subjects, and (2) involve only procedures listed in one or more of the specific categories listed in the regulations at Federal Register Volume 63, No 216.

 

Specific Policies

  1.1 Research Categories Eligible for Expedited Review

(1) Clinical studies of drugs and medical devices only when condition (a) or (b) is met.

(a) Research on drugs for which an investigational new drug application (21 CFR Part 312) is not required. (Note: Research on marketed drugs that significantly increases the risks or decreases the acceptability of the risks associated with the use of the product is not eligible for expedited review.)

(b) Research on medical devices for which (i) an investigational device exemption application (21 CFR Part 812) is not required; or (ii) the medical device is cleared/approved for marketing and the medical device is being used in accordance with its cleared/approved labeling.

(2) Collection of blood samples by finger stick, heel stick, ear stick, or venipuncture as follows:

(a) From healthy, non-pregnant adults who weigh at least 110 pounds. For these subjects, the amounts drawn may not exceed 550 ml in an 8 week period and collection may not occur more frequently than 2 times per week; or

(b) From other adults and children2, considering the age, weight, and health of the subjects, the collection procedure, the amount of blood to be collected, and the frequency with which it will be collected. For these subjects, the amount drawn may not exceed the lesser of 50 ml or 3 ml per kg in an 8 week period and collection may not occur more frequently than 2 times per week.

(3) Prospective collection of biological specimens for research purposes by noninvasive means.

Examples: (a) hair and nail clippings in a non-disfiguring manner; (b) deciduous teeth at time of exfoliation or if routine patient care indicates a need for extraction; (c) permanent teeth if routine patient care indicates a need for extraction; (d) excreta and external secretions (including sweat); (e) uncannulated saliva collected either in an unstimulated fashion or stimulated by chewing gumbase or wax or by applying a dilute citric solution to the tongue; (f) placenta removed at delivery; (g) amniotic fluid obtained at the time of rupture of the membrane prior to or during labor; (h) supra- and subgingival dental plaque and calculus, provided the collection procedure is not more invasive than routine prophylactic scaling of the teeth and the process is accomplished in accordance with accepted prophylactic techniques; (i) mucosal and skin cells collected by buccal scraping or swab, skin swab, or mouth washings; (j) sputum collected after saline mist nebulization.

(4) Collection of data through noninvasive procedures (not involving general anesthesia or sedation) routinely employed in clinical practice, excluding procedures involving x-rays or microwaves. Where medical devices are employed, they must be cleared/approved for marketing. (Studies intended to evaluate the safety and effectiveness of the medical device are not generally eligible for expedited review, including studies of cleared medical devices for new indications.)

Examples: (a) physical sensors that are applied either to the surface of the body or at a distance and do not involve input of significant amounts of energy into the subject or an invasion of the subject’s privacy; (b) weighing or testing sensory acuity; (c) magnetic resonance imaging; (d) electrocardiography, electroencephalography, thermography, detection of naturally occurring radioactivity, electroretinography, ultrasound, diagnostic infrared imaging, doppler blood flow, and echocardiography; (e) moderate exercise, muscular strength testing, body composition assessment, and flexibility testing where appropriate given the age, weight, and health of the individual.

(5) Research involving materials (data, documents, records, or specimens) that have been collected, or will be collected solely for non-research purposes (such as medical treatment or diagnosis). (NOTE: Some research in this category may be exempt from the HHS regulations for the protection of human subjects. 45 CFR 46.101(b)(4). This listing refers only to research that is not exempt.)

(6) Collection of data from voice, video, digital, or image recordings made for research purposes.

(7) Research on individual or group characteristics or behavior (including, but not limited to, research on perception, cognition, motivation, identity, language, communication, cultural beliefs or practices, and social behavior) or research employing survey, interview, oral history, focus group, program evaluation, human factors evaluation, or quality assurance methodologies. (NOTE: Some research in this category may be exempt from the HHS regulations for the protection of human subjects. 45 CFR 46.101(b)(2) and (b)(3). This listing refers only to research that is not exempt.)

 

Norman Campus IRB Additional Clarification:

 

Behavioral research involving deception may qualify for expedited review provided that it meets the following criteria:

·        The description of the study contains no false statements, but may omit specific information that may bias responses,

·        It involves no greater than minimal risk,

·        It does not involve protected groups,

·        It does not involve material that is sensitive or personal in nature, and

·        A debriefing is provided at completion that explains fully the purpose of the study and gives the participant the opportunity to withdraw his/her participation by means of requesting that his/her data be withdrawn from the study.

(8) Continuing review of research previously approved by the convened IRB as follows:

(a) where (i) the research is permanently closed to the enrollment of new subjects; (ii) all subjects have completed all research-related interventions; and (iii) the research remains active only for long-term follow-up of subjects; or

(b) where no subjects have been enrolled and no additional risks have been identified; or

(c) where the remaining research activities are limited to data analysis.

(9) Continuing review of research, not conducted under an investigational new drug application or investigational device exemption where categories two (2) through eight (8) do not apply but the IRB has determined and documented at a convened meeting that the research involves no greater than minimal risk and no additional risks have been identified.

1.2  Definition of Minimal Risk

          Minimal risk is 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 examinations or tests….”

1.3  Cautions

A.      Activities listed in Section 1.1 should not be deemed to be of minimal risk simply because they are included on the list of eligible research.  Inclusion on this list merely means that the activity is eligible for review through the expedited review procedure when the specific circumstances of the proposed research involve no more than minimal risk to human subjects.

B.      Expedited review procedure may not be used where identification of the subjects and/or their responses would reasonably place them at risk of criminal or civil liability or be damaging to the subjects' financial standing, employability, insurability, reputation, or be stigmatizing, unless reasonable and appropriate protections will be implemented so that risks related to invasion of privacy and breach of confidentiality are no greater than minimal.  Furthermore, the expedited review procedure may not be used for classified research involving human subjects.

1.4  Authority of the IRB Chairperson

The IRB Chairperson or designee may exercise all of the authorities of the IRB, except that he/she may not disapprove the research.  A research project may be disapproved only after review by the convened IRB.

1.5  Notification of the IRB

When the expedited review procedure is used, the IRB office will inform the Investigator of the Chair’s expedited review decision including notification of the qualifying category for expedited review. All regular members will be informed of the actions taken by the IRB chairperson or designee at their next convened meeting as the meeting agenda will reflect those items approved under an expedited review. IRB discussion will be limited unless there are questions.

1.6  Documentation

If the study qualifies for expedited review, the IRB Chairperson or designee will document his/her determination of risk.

The minutes will include documentation of the studies that were reviewed via expedited review and any issues resolved relating to questions that IRB members had concerning the research reviewed.

1.7  Additional Items That May be Reviewed by the Chairperson or Designee

A.     Conditional approval pending minor revisions, clarification:  Revisions to consent documents and other documentation or clarifications submitted as a result of full IRB review and as a condition to final approval may be reviewed by the IRB Chairperson or his/her designee. However, the convened IRB should review responses to requests that require judgments not allowable under the expedited review procedure; i.e. responses to DSMB plans, major rewrites to the informed consent document, rationale for the number or type of study participants being sought. 

B.     Continuing Review:  The IRB Chair, or designee, may use the expedited review procedure for Continuing review of research previously approved by the convened IRB where:

(a) the research is permanently closed to the enrollment of new subjects; (ii) all subjects have completed all research-related interventions; and (iii) the research remains active only for long-term follow-up of subjects; or

(b) no subjects have been enrolled and no additional risks have been identified; or

(c) the remaining research activities are limited to data analysis.

C.    Initial review of serious adverse event and safety reports (SAEs): The IRB Chairperson, or designee, will review summaries of safety reports and reports of serious adverse events.  If the IRB Chairperson determines that action is needed to protect the safety of research participants due to the nature or frequency of reported adverse events, he/she may take such action to the convened IRB or designated Data Safety Monitoring Board subcommittee, which will review the adverse events and study in question to determine action, if any, by the IRB.  If the IRB Chairperson determines that the information reviewed in the SAEs poses an immediate threat to study participants, he/she may take immediate action such as suspending enrollment or discontinuing study treatment. 

D.    Amendments: These include revisions to the consent form, translations of the consent form, advertisements, or minor changes to the previously approved project that do not involve more than minimal risk to participants.  Any protocol revision that entails more than a minimal risk to the subjects must be reviewed by the full IRB at a convened meeting.

E.     Advertisements: The IRB Chairperson, or designee, may approve new or revised recruitment advertisements or scripts.

F.     Revisions to informed consent documents:  Minor changes to informed consent documents that do not affect the rights and welfare of study participants, or do not involve increased risk or significant changes in study procedures may be reviewed and approved by the Chairperson/designee.

G.    Miscellaneous items:  These items do not include amendments, adverse events or continuing reviews but may include protocol deviations, discussion topics such as an audit result, Investigator question or Investigator correspondence. Miscellaneous items may be reviewed and approved by the IRB Chairperson or designee if it does not increase risks to participants.

2.  SCOPE

These policies and procedures apply to all research submitted to the IRB(s) that qualifies for expedited review.

3.  RESPONSIBILITY

IRB Coordinator is responsible for the initial identification of submissions that qualify for expedited review. IRB Chairperson (or designee) is responsible for making the final determination of eligibility.

IRB Chairperson (or designee) is responsible for conducting expedited review.

IRB Coordinator is responsible for posting of the expedited reviews to the agenda/minutes for presentation and review by the IRB members.

4.  APPLICABLE REGULATIONS AND GUIDELINES

Minimal Risk:               45 CFR 46.102

    21 CFR 56.102

Expedited Review:    45 CFR 46.110

21 CFR 56.110

FDA Information Sheets, 1998

OHRP IRB Guidebook

5.  REFERENCES TO OTHER APPLICABLE SOPs

This SOP affects all other SOPs.

6.  ATTACHMENTS

402-A          Expedited Review Categories

7.  PROCESS OVERVIEW

 

7.1  IRB Chairperson or designee determines risk according to the Research Categories listed in this policy.  The IRB Chairperson considers the methods used to conduct the research, recruitment practices, participant population, confidentiality of data, involvement and training of the research staff and feasibility of the study when considering if a study is minimal risk.

7.2  IRB Chairperson or designee may exercise all of the authority of the IRB,  except that only the convened IRB may disapprove a research proposal.  The IRB Chairperson or designee may request changes or approve the research proposal.

7.3  IRB Coordinator provides to the IRB Chairperson or designee the item to be reviewed and the tools to conduct the review.

7.4  IRB Chairperson or designee documents in writing his/her determination of risk on the IRB Application Form by stamping and initialing his/her approval, including the assigned expedited number. The IRB Coordinator posts the expedited review research proposal to the next appropriate Board agenda.

7.5  IRB Chairperson or designee documents in writing his/her minor revisions inside the file folder on the yellow note sheet or, if revisions are approved, stamps and initials his/her approval on the IRB Application Form, amendment form, adverse events and safety reports and miscellaneous item.

7.6  IRB Chairperson (or designee) reviews minor changes in research, revisions to informed consent documents, adverse events and safety reports, and advertisements.

7.7  If minor changes or revisions entail more than minimal risk, IRB Chairperson documents on the yellow note sheet to assign to full IRB review. The IRB Coordinator posts the revision to the next appropriate Board agenda.

7.8  If minor changes are approved, IRB Chairperson stamps and initials his/her approval on the revised document. The IRB Coordinator posts the approval to the next Board agenda and generates an approval letter.

7.9 Once the Chairperson or designee approves the expedited study, the IRB Coordinator posts the expedited review research proposal to the next appropriate Board agenda thereby informing all regular members of the review and approval.

 

8.  PROCEDURES EMPLOYED TO IMPLEMENT THIS POLICY

A.  Expedited Review  - New Study

Who

Task

Tool

IRB Chairperson

 

Make final determination regarding qualification for expedited review. 

Document on application form expedited category.

402-A Expedited Review Categories

IRB Coordinator

 

 

 

 

Based on application materials submitted, forward to IRB Chairperson for expedited review.

Upon completion of the review, add the item to the next IRB Meeting agenda/minutes and indicate the outcome.

 

 

B.  Expedited Review  - Continuing Review, Board requested changes, Miscellaneous items or other items determined by the Chairperson appropriate for Expedited review.

Who

Task

Tool

IRB Chairperson

Perform primary review; using all appropriate worksheets.

402-A Expedited Review Categories

IRB Coordinator

Upon completion of the review, add the study to the next IRB Meeting Agenda/Minutes and indicate the outcome.

 

 

 

C.  Expedited Review  - Amendments

Who

Task

Tool

IRB Coordinator

 

Review and make initial determination regarding qualification for expedited review.   Forward to Chair for review.

Upon completion of the review, add the amendment to the IRB Meeting Agenda and indicate the outcome of the review.

Print appropriate letter(s) for Chairperson signature.

402-A Expedited Review Categories

IRB Chairperson or Designee

Perform primary review; using appropriate worksheets.

402-A Expedited Review Categories

 


 

SOP: 403

Version No: 1

·          Effective Date: 07/01/2005

Initial Review - Criteria for

IRB Approval

Supercedes Document Dated: 10/15/04

1.  POLICY

All research projects that intend to enroll human participants must meet certain criteria before study-related procedures can be initiated.  The criteria are based on the principles of justice, beneficence and autonomy as discussed in the Belmont Report and are specified below.  In addition, certain other criteria that are unique to The University of Oklahoma may apply and must be met as well.

No Investigator has a right to conduct research within this institution.  Rather, it is a privilege granted by society as a whole and the Board of Regents of the University of Oklahoma in particular. 

The IRB evaluates each project on an individual basis in order to assess whether the Investigator is providing all of the necessary services in an effort to protect the participant.  This may include research staff, social support services, counseling, ancillary care, equipment, and training provided by the Investigator to external or internal entities involved in the research project.

This assessment will be ascertained using the initial IRB application which includes the protocol, outside IRB approval letters, letters of support, advertisements, and all other supporting documents. The IRB will consult the Investigator for additional information regarding necessary services. 

During the course of review by the IRB, the research project will be evaluated to determine whether it provides adequate resources to protect the rights and welfare of participants.

 

Specific Policies

1.1  Minimal Criteria for Approval of Research

In order for a research project to be approved, the IRB must find that: 

A.  Risks to participants are minimized:

·          By using procedures that are consistent with sound research design and which do not unnecessarily expose participants to risk, and

·          Whenever appropriate, by using procedures already being performed by or on the participants for diagnostic or treatment purposes.

B.      Risks to participants are reasonable in relation to anticipated benefits, if any, to participants, and the importance of the knowledge that may be expected to result.

·          In evaluating risks and benefits, the IRB will consider those risks and benefits that may result from the research (as distinguished from risks and benefits of therapies that participants would receive even if not participating in the research).

·          The IRB will also consider the data and safety monitoring plan, if applicable.  The IRB will suggest a DSMP to the Investigator, if applicable, to ensure patient safety.

C.    Selection of participants is equitable.

§         The IRB should take into account the purpose(s) of the research, the setting in which the research will be conducted and the inclusion/exclusion criteria so that fair and equitable burdens and benefits are maximized.  The IRB should evaluate the recruitment practices and also any payments to participants.  The IRB should also be particularly cognizant of the special problems of research involving vulnerable populations, such as children, prisoners, pregnant women, handicapped, or mentally disabled persons, or economically or educationally disadvantaged persons.

D.    Informed consent/assent will be sought from each prospective participant or the participant's legally authorized representative, in accordance with and to the extent required by appropriate local, state and federal regulations.

E.    Informed consent/assent will be appropriately documented as required by local, state and federal regulations.

F.    If the protocol has, or has the potential to have, higher levels of risk, the research plan makes adequate provision for monitoring the data collected to ensure the safety of participants.

G.    Where appropriate, there are adequate provisions to protect the privacy of participants and to maintain the confidentiality of identifiable data.

H.    When some or all of the participants, such as children, prisoners, pregnant women, handicapped, or mentally disabled persons, or economically or educationally disadvantaged persons, are likely to be vulnerable to coercion or undue influence or for participants found at international sites, additional safeguards have been included in the study and in the IRB review process, to protect the rights and welfare of these participants.

I.      Studies are reviewed at periods appropriate to the degree of risk research participants are exposed to due to their participation in the study, but at least annually.


1.2  Other Criteria

The IRB may require verification of information submitted by an Investigator. The need to verify any information will be determined by the IRB at a convened meeting or at the discretion of the Expedited reviewer. The purpose of the verification will be to provide necessary protection to participants when deemed appropriate by the IRB.

The criteria used to determine whether third-party verification is required may include:

·          Investigators that conduct studies that involve a potential high risk to participants,

·          Studies that involve vulnerable populations,

·          Investigators who conduct studies that involve large numbers of participants, and

·          Investigators selected at the discretion of the IRB.

Projects that need third party verification, from sources other than the Investigator that no material changes have occurred since previous IRB review was determined, will have such assessment performed as necessary.

1.3  Reliance on Other IRBs for Review and Approval of Research Conducted at The University of Oklahoma.

Under authority granted by the Board of Regents of The University of Oklahoma, the Senior Vice President and Provost of the Health Sciences Center and the Senior Vice President and Provost of the Norman campus may enter into joint review arrangements, rely upon the review of another qualified IRB, or make similar arrangements for avoiding duplication of effort as allowed and upon modification of the institutional Federal-wide Assurance agreements (FWA).  For example, projects determined to have a conflict of interest, IRB review may be waived and delegated to Western Institutional Review Board (WIRB).

1.4  Reciprocal Review and Approval of Research Conducted at one of the University of Oklahoma Campuses.

A.  Determination of Reviewing Campus

The reviewing campus shall be determined in the following manner:

1.      For medical or clinical studies involving human participants, the Oklahoma City Campus IRB will review for both campuses. 

2.  For all other research activities, determination of the reviewing campus is based on the home campus of the Investigator unless it involves clinical procedures that are outside of the expertise of the Norman Campus IRB.  For example, a Norman Campus Investigator from the College of Education proposes to conduct a behavioral research project but intends to recruit from the Oklahoma City campus, the Norman Campus IRB will provide IRB review.

2.      Each campus shall have the right to require review by its own IRB regardless of this policy, provided that the decision is stated in writing and presented to the IRB Chairpersons of both IRBs.

1.5   Review of Research Conducted by Persons Carrying Appointments from University of Oklahoma Faculty at non-University facilities.

Research carried out by individuals with University of Oklahoma affiliations impacts the University, even if it is not conducted at University facilities.  Any individual, who has a University appointment, whether full or part-time, salaried or voluntary, as staff or faculty member, is required to notify the appropriate IRB of his/her plans to conduct research.  The IRB Chairperson, or designee, shall review such activities and determine whether the rights and safety of the participants have been adequately considered by another IRB.  If no IRB review has taken place, or if the IRB Chairperson (or designee) has sufficient concerns about the study, the research should not proceed until those concerns have been adequately addressed by the IRB Chairperson or the convened IRB. A copy of the annual review and approval of the research provided by an outside IRB shall be provided to the IRB, until the study is closed.

 

1.6    Length of Approval

Once approved by the IRB, the IRB must determine the appropriate length of the approval.  This is the maximum number of days that the IRB feels is appropriate for the study to continue without full review of the research.  Federal regulations do not allow for this approval period of time to exceed 365 days.

1.         If the IRB determines that the risk to participants is appropriate based on the procedures outlined in the protocol and that the majority of potential risks is currently known, then approval will be granted not to exceed one year.

2.         If the IRB determines that the study involves a high degree of risk and/or the stage of the research is such that many of the potential risks are not yet known, then approval may be granted for a shorter amount of time. The duration of approval will vary depending on the type of study, the projected enrollment, the study population, etc.  The duration of approval and research for such determination will be noted in the IRB minutes.  The IRB will also ensure that an appropriate data safety monitoring system is in place.

3.         Certain types of research will not fit clearly into one of the above categories.  These may include Phase I research studies, special treatment IND protocols where the purpose is to provide compassionate treatment, or other types of research where approval for a certain period of time would not be appropriate to assure that appropriate continuing review is conducted.  In these cases, the IRB will grant approval for enrollment of a specific number of participants (not to exceed a certain period of time) prior to continued enrollment. These specific conditions and reasons for limitations will be noted in the minutes and communicated to the Investigator.  

 

1.7     Scientific Review

1.   All cancer-related studies will be reviewed by the Cancer Center Scientific Review Committee (SRC) prior to submission to the IRB. 

2.      Investigator-initiated studies which plan to utilize the General Clinical Research Center (GCRC) which are not cancer related will be presented for scientific merit review to the General Clinical Research Center Advisory Committee (GAC) before submission to the IRB.

3.      All studies utilizing the OKC or Muskogee VA facility or participants will be reviewed by the VA Research and Development (VA R&D) Committee .

4.      The Institution will utilize the expertise and knowledge of the IRB to review proposed research for either scientific merit or scholarly review for the following human research activities:

a.      Investigator-initiated studies that are not utilizing the GCRC,

b.      Studies that are not cancer related,

c.      All other research projects that require scientific merit or scholarly review.

 

Scientific or scholarly review of proposed research activities by the IRB will be assessed for merit using a scientific review checklist.  Comments and recommendations by the IRB will be made in writing to the Principal Investigator.  When necessary, the IRB will obtain additional expertise from a consultant(s).  Such a consultant will be independent of both the investigator and the protocol.

2.  SCOPE

These policies and procedures apply to all IRB staff and IRB members and to research submitted to the IRB.

3.  RESPONSIBILITY

IRB Coordinator is responsible for ensuring that IRB members have all the tools and resources they need to complete their research reviews.

IRB Chairperson (or designee) is responsible for providing IRB members adequate submission review training and ongoing guidance, and for selecting primary and secondary reviewers with the relevant expertise to perform reviews and make necessary recommendations on approval decisions by the IRB.

IRB Reviewer is responsible for conducting a thorough review, securing appropriate consulting expertise as needed, and making appropriate approval recommendations for consideration by the IRB.

IRB Education Coordinator is responsible for the initial and continuing education of the IRB Board members.

4.  APPLICABLE REGULATIONS AND GUIDELINES

45 CFR 46.111

21 CFR 56.108, 56.111

5.  REFERENCES TO OTHER APPLICABLE SOPs

This SOP affects all other SOPs.

6.  ATTACHMENTS

403-A     IRB New Study Reviewer Sheet

403-A-1  Proposal Review Form

7.  PROCESS OVERVIEW

7.1.1       The IRB Coordinator receives new application documents and checks for accuracy of information, as well as all required documents are submitted.  The IRB Coordinator makes an initial assessment of the study to determine if it requires review by expedited procedures or a convened IRB.  The study is either assigned to the next appropriate agenda or given to the Chair for review. 

7.1.2       The IRB Chairperson, or designee, reviews the content with consideration of the risk/benefit analysis, the design in the selection of subjects, and the inclusion of required information elements in the informed consent according to federal ‘Common Rule’ regulations, The Belmont Report, as well as local and state regulations.  If the study requires full Board review, the IRB Chairperson remits back to the IRB Coordinator, who in turn assigns the study to the next appropriate Board agenda.

7.1.3       The IRB Chairperson may require verification of information submitted by an Investigator.  This information may be obtained from third party persons such as the sponsor, other institutions participating in the research and other IRBs reviewing the research.  The IRB Chairperson will document this verification on the yellow note sheet in the file or may dictate a note to file.

7.1.4       As noted, the University of Oklahoma Senior Vice President and Provost of the Health Sciences Center and the Senior Vice President and Provost of the Norman campus may enter into joint arrangements and rely upon review of another qualified IRB.

7.1.5       The IRB Coordinator ensures in advance that the IRB Chairperson and all reviewers receive an agenda for each IRB meeting, copies of the previous IRB meeting minutes, and copies of all agenda items to be reviewed at the meeting.

7.1.6       The IRB Coordinator in advance of the IRB meeting forwards an agenda to the IRB Chairperson to designate primary and secondary reviewers for each item to be reviewed at the meeting. The IRB Coordinator inserts the name of each primary and secondary reviewer in the agenda and forwards the agenda to each assigned reviewer.

7.1.7       The IRB Reviewer examines each assigned agenda item and reports their conclusions to the IRB Chairperson and other IRB members at the Board meeting. The IRB Coordinator notates their conclusions in the Board meeting minutes.

7.1.8       All expedited proposals follow the expedited process outlined in SOP 402.

8.  PROCEDURES EMPLOYED TO IMPLEMENT THIS POLICY

 

Who

Task

Tool

IRB Coordinator

Verify all information submitted is in accordance with SOP 302.

Post project to next available Board Meeting agenda.

Provide primary and secondary reviewers with appropriate protocol review worksheet.

Document the review in the Minutes.

SOP 302

 

IRB Reviewer Sheet

IRB Chairperson or designee

Select reviewers with appropriate expertise for the research to be reviewed.

 

IRB Member (Reviewer)

Review research proposal and summarize findings on appropriate protocol review worksheet.

Ascertain whether any special considerations exist that may influence the review of a project.

Ascertain whether the evidence exists that third party verification of submitted information is needed.

Present summary of findings and recommendations at the next convened IRB meeting.

 

 

 

Refer to Section 500

 

Refer to SOP 403

 


 

SOP: 404

Version No: 1

Effective Date: 07/01/2005

·           

·          Continuing Review

 

Supercedes Document Dated: 10/15/04

1.  POLICY

The IRB conducts continuing review of research taking place within its jurisdiction at intervals appropriate to the degree of risk.  Periodic review of research activities is necessary to determine whether approval should be continued or withdrawn.  All research involving human participants must be reviewed no less than once per year.

IRB approval may be withdrawn at any time if warranted by the conduct of the research.  The regulations authorize IRB to establish procedures for the concurrent monitoring of research activities involving human participants.

IRB approval for the conduct of a research project may be revoked if the risks to the participants are determined to be unreasonably high, for example, more than an expected number of adverse events, unexpected serious adverse events; Investigator and/or research staff has not completed the education requirements or evidence that the Investigator is not conducting the investigation in compliance with IRB or Institutional guidelines. 

Such findings may result in more frequent review of the research project to determine if approval should be withdrawn or enrollment stopped until corrective measures can be taken or the research project terminated.

 

Specific Policies

1.1  Determining Appropriate Interval for Continuing Review

The IRB must conduct continuing review of research projects for purposes of renewal of the IRB approval period, at intervals appropriate to the degree of risk, which is determined at the initial review, but not less than once per year. “Not less than once per year" means that the research must be reviewed and approved on or before the one‑year anniversary of the previous IRB review date, even though the research activity may not have begun until some time after IRB granted approval.

Investigators or qualified designees are required to submit a periodic report prior to the expiration of the research project or as specified by the IRB, but at least once per year. 

Oklahoma City Campus:  The report should be filed with the IRB office approximately 75 days before the research project approval period ends.

Norman Campus:  The report should be filed with the IRB office approximately 45 days before the research project approval period ends.

 

1.2  Extensions of Approval Period

There is no grace period extending the conduct of the research beyond the expiration date of IRB approval.  Extensions beyond the expiration date will not be granted.  If the IRB Application for Continuing Review (Progress Report) and other supporting documents are not received as scheduled, the Investigator must stop enrollment and research project activities until reports are reviewed and approved.  The IRB will notify the Investigator to stop research project activities.

However, if the Investigator is in communication with the IRB, the Continuing Review Report or other report is forthcoming, and in the opinion of the IRB Chairperson, participants in the research project would suffer a hardship if medical care were discontinued, appropriate medical care may continue beyond the expiration date for a reasonable amount of time. However, new participants cannot be enrolled. 

The IRB will address on a case-by-case basis those rare instances where failure to enroll new participants would seriously jeopardize the safety or well being of an individual.  Prospective research data cannot be collected nor can research-related procedures be performed until a Continuing Review Report is reviewed and approved.

 

1.3  Continuing Review Criteria

Continuing review must be substantive and meaningful. When considering whether or not to renew a research project, the IRB revisits the same criteria used to grant initial approval.  Therefore, the IRB (or the reviewers for protocols reviewed under an expedited procedure) must determine that:

·        The risks to participants continue to be minimized and reasonable in relation to the anticipated benefits;

·        The selection of participants continues to be reasonable in relation to anticipated benefits;

·        Informed consent continues to be appropriately documented;

·        Provisions for safety monitoring of the data are adequate;

·        Protections to ensure the privacy of participants and confidentiality of identifiable data, and

·        Safeguards for vulnerable populations are appropriate;

·        The Investigator is providing all of the necessary services to conduct the research project;

Because it may be only after research has begun that the real risks can be evaluated and the preliminary results used to compute the actual risk/benefit ratio; the IRB can then determine whether or not the research project can be renewed at the same risk/benefit ratio, or if new information has changed that determination.

In order to determine the status of the research project, the following will be revisited:

1.3.1 Consent document:  each member of the IRB shall review the currently approved consent document and ensure that the information is still accurate and complete. Any significant new findings that may relate to the participant’s willingness to continue in the research project should be provided to the participant in an updated consent document or discussed with the participant.

1.3.2    Current approved protocol including any amendments to the protocol since initial review:  each member of the IRB shall receive the currently approved protocol including any amendments previously approved by the Board.  Amendments and changes to a research protocol should be submitted as generated during the course of the research project. 

1.3.3  Application for Continuing Review:  all IRB members shall receive a Continuing Review report prepared and submitted by the Investigator along with the number of participants entered to date and since the last review.  The Continuing Review report shall summarize:

o       adverse event experiences,

o       any unanticipated problems involving risks to participants or others

o       any withdrawal of participants from the research or complaints about the research,

o       a summary of any relevant recent literature,

o       interim findings and amendments or modifications to the research since the last review,

o       any relevant multi-center trial report, any other relevant information, especially information about risks associated with the research,

o       a copy of the current informed consent document

o       and provide a reassessment of the risk-to-benefit ratio.  See the Adverse Event policy 406 (Adverse Events).

 

Continuing review of DSMB-monitored clinical trials:  when a clinical trial is subject to oversight by a DSMB whose responsibilities include review of adverse events, interim findings and relevant literature (e.g., DSMB’s operating in accordance with the National Cancer Institute Policy for Data and Safety Monitoring of Clinical Trials), the IRB conducting continuing review may rely on a current statement from the DSMB indicating that it has reviewed research project-wide adverse events, interim findings and any recent literature that may be relevant to the research, in lieu of requiring that this information be submitted directly to the IRB. 

The IRB must still receive and review reports of local, on-site related, serious and unanticipated problems involving risks to participants or others and any other information needed to ensure that its continuing review is substantive and meaningful.

1.4  Possible Outcomes of Continuing Review

As an outcome of continuing review, the IRB may require that the research be modified or halted altogether.  If it is recommended that the research project be terminated or suspended, the IRB will address and describe how the Investigator will proceed with termination taking into account the rights and welfare of the current participants (if applicable).  The IRB may need to impose special precautions or relax special requirements it had previously imposed on the research project.

1.5  Expedited Review for Renewal

A research project that was originally reviewed using the expedited review procedure may receive its continuing review on an expedited basis.  Additionally, a research project that was reviewed by the convened IRB that has not been awarded funding, or remains open only to data analysis may be reviewed using an expedited review.

The IRB Chairperson or designee conducts the review on behalf of the full IRB using the same criteria for renewal as stated in section 1.3 of this policy.  If the reviewer feels that there has been a change to the risks or benefits, he or she may refer the research project to the convened IRB for review.

2.  SCOPE

These policies and procedures apply to all research submitted to the IRB.

3.  RESPONSIBILITY

IRB Staff is responsible for notifying investigators to submit their continuing review reports.

HRPP Director is responsible for establishing and implementing processes for making research renewal decisions.

IRB is responsible for timely and thorough review of the Application for Continuing Review, communication to the Investigator of any needed changes, and approval prior to the expiration date.

4.  APPLICABLE REGULATIONS AND GUIDELINES

21 CFR 56.108,111

45 CFR 46.111

     OHRP Guidance on Continuing Review 07/11/02.

 

  5.       REFERENCES TO OTHER APPLICABLE SOPs

This SOP affects all other SOPs.

6.  ATTACHMENTS

302-B                Application for Continuing Review

601-V                Continuing Review Reminder Notice Letter

601-W               Continuing Review Final Notice Letter

 

7.  PROCESS OVERVIEW

7.1    Continuing review of research is conducted at intervals appropriate to the degree of risk, but not less than once per year.  Research must be reviewed and approved on or before the one‑year anniversary date of the previous IRB review date.

7.2    The anniversary date is determined at initial review depending on the level of risk.  At the time of approval, the research project is given an approval-through date and recorded in the IRB database.  Investigators or qualified designees are required to submit an Application for Continuing Review report before the expiration of the study or as specified by the IRB, but at least once per year. 

         Oklahoma City Campus: the report should be filed with the IRB office 75 days before the end of the research project approval period.

         Norman Campus:  the report should be filed with the IRB office 45 days before the end of the research project approval period.

7.3    Monthly reports from the IRB database are generated based on the expiration date.  The report lists the Continuing Reviews due by the month of expiration.  First reminder notices are generated from the database 90 days prior to expiration with a due date of the 15th of the month or the next business day.

7.4    Final reminder notices are generated 2-3 days after the first due date with a new due date within 7 days.  If after 7 days the Investigator fails to submit the Continuing Review report the Investigator is notified by email and/or telephone calls. 

7.5    Federal regulations do not allow for a grace period or extension of the approval period.  If the Continuing Review is not reviewed and approved by the end of the approval period the Investigator may not continue enrollment or other research activity.  The Investigator is responsible for notifying the IRB if there is a need to continue enrollment of new participants for their safety and well being.

7.6    When the Continuing Review report is received in the IRB office, it is first reviewed for completeness and triaged for type of review.   All Expedited Continuing Reviews are given to the IRB Chairperson for review.  The Continuing Reviews for the convened IRB are added to the next appropriate meeting agenda for review.

7.7    IRB members are given a Continuing Review Worksheet to ensure meaningful and substantive review.  All documents included with the Continuing Review Report will be provided to all IRB members.  This includes the Continuing Review report, protocol, consent form(s), Research Authorization forms, and all documents as outlined in the Continuing Review report.

7.8    Review by the Convened IRB: the convened IRB reviews all documents at the meeting and makes recommendations for approval, contingent approval, deferral or disapproval as follows:

o       Approval:  if the IRB approves the Continuing Review without revisions, the IRB Coordinator generates an approval letter for signature by the IRB Chairperson. 

o       Contingent Approval: if the IRB determines minor changes are required, the IRB Coordinator generates a Contingent Approval letter notifying the Investigator of the requested changes.  When the changes are returned, the IRB Coordinator reviews the changes for completeness.  The IRB Coordinator notates any deficiencies or discrepancies for the IRB Chairperson and forwards the Continuing Review report to the IRB Chairperson for review.  If the board requested changes are not received before the expiration date, the IRB Coordinator will generate a notice of expiration letter.

o       Deferral:  the IRB may determine that substantive clarifications or modifications regarding the protocol or informed consent documents are required.  In these cases the IRB will defer approval, pending subsequent review by the convened IRB of responsive material.  The IRB Chairperson will contact the Investigator concerning the details of the deferral and will draft the deferral letter.

o       Once changes are received in the IRB office, the IRB Coordinator will place the Continuing Review on the next appropriate meeting agenda.  The IRB Coordinator will evaluate whether there will be a lapse in IRB approval.  If there will be a lapse in IRB approval, the IRB Coordinator will print the Notice of Expiration letter for signature by the IRB Chairperson. 

o       Disapproval: the IRB may identify serious concerns for participant safety or Investigator compliance.  In these cases, the Board will disapprove the research.  The IRB Chairperson will draft the disapproval letter and the IRB Coordinator will generate the disapproval letter for transmittal to the Investigator

 

7.9       Expedited Review of Continuing Reviews:  the IRB Chairperson reviews all continuing review documents received and will either approve or contingently approve the Continuing Review.   The IRB Chairperson may also determine that the Continuing Review should be presented for review by the convened IRB.  The IRB Chairperson may not disapprove a Continuing Review.

o       Approval:  if the IRB Chairperson approves the Continuing Review without changes, the IRB Coordinator generates an approval letter for signature of the IRB Chairperson. 

o       Contingent Approval:  if the IRB Chairperson determines that minor changes are required, the IRB Coordinator generates an email to notify the Investigator of the contingent approval and the revisions requested by the IRB Chairperson.  If the IRB Chairperson determines that the convened Board should review the Continuing Review, the IRB Coordinator will assign the item to the next appropriate meeting agenda.

 

 

 

 

 

 

 

7.10    Determination of Approval & Expiration Dates:  following approval of a research project, the approval and expiration dates are determined as shown in the following examples:

 

                  IRB Action:  Approval

                  Convened IRB Meeting Date:          March 15, 2004

                  Approval Date:                                March 15, 2004

                  Expiration Date:                             February 28, 2005  (last day of the month prior to the month of approval)

 

                 

                  IRB Action:  Contingent Approval

                  Convened IRB Meeting Date:          March 25, 2004

                  Date revisions returned:                   March 30, 2004

                  Approval Date (by Chairperson):    April 7, 2004

                  Approval Date:                                April 7, 2004

                  Expiration Date:                             February 28, 2005 (determined from the meeting date)

 

 

                  IRB Action:  Deferral

                  Convened IRB Meeting Date:          March 15, 2004

                  Requested revisions submitted:      March 30, 2004

                  Resubmitted to convened IRB:        April 17, 2004

                  IRB Action: Contingent Approval

                  Requested revisions submitted:      May 5, 2004

                  Approval Date (by Chairperson):    May 7, 2004

                  Approval Date:                                May 7, 2004

                  Expiration Date:                             February 28, 2005 (determined from the date of the first meeting)                    

 

 

 

 

 

 

8.  PROCEDURES EMPLOYED TO IMPLEMENT THIS POLICY

 

Who

Task

Tool

Administrative Assistant

The first of each month, generate a summary for the entire month of the studies with IRB approvals due to expire in 90 days.

Generate corresponding notification letters, and labels from the database per SOP 601. 

Mail reminder letters to Investigators at least 90 days prior to the expiration date.

Continuing Review Reminder Notice Letter

IRB Coordinator

During the second week of each month, generate a summary for the entire month of the Continuing Reviews due to expire in 2 weeks and the corresponding expiration letters from the database per SOP 601.  The Investigator must submit an Application for Continuing Review Form to the IRB within 2 weeks of the expiration date.  Inactivation of the study by the Chair will occur after this 10-day deadline.

Continuing Review Final Notice

 

 

IRB Member(s)

When the Application for Continuing Review is received, the IRB and/or its designee will review the report and associated materials to determine the status of continuation of the study.

Continuing Review Worksheet

IRB Coordinator

The IRB Coordinator will notify the Investigator of the outcome of the study per SOP 601.

 

 

 

 

 

 


 

SOP: 405

Version No: 1

Effective Date: 07/01/2005

·          AMENDMENTS

Supercedes Document Dated: 10/15/04

 1.  POLICY

Any modifications or changes to the previously approved research project such as changes to the inclusion/exclusion criteria, study population, study procedures or consent process, requested by the investigator or sponsor, must be approved by the IRB before the revisions are implemented. Such modifications or changes are also known as amendments.

Specific Policies

1.1 Definitions of Minor Modifications

Modifications that do not materially affect an assessment of the risks and benefits of the study or substantially change the specific aims/design of the study will be considered minor and will qualify for expedited review.  Examples of minor modifications include, but are not limited to:

·        Addition of research activities that would be considered exempt or expedited if considered independent from the main research protocol;

·        Minor increases or decreases in the number of participants;

·        Narrowing or broadening the inclusion criteria;

·        Changing the dosage form (i.e. tablet to capsule or oral liquid) of an administered drug provided that the dose and route of administration remains constant.

·        Decreasing the number of biological sample collections, provided that such a change does not affect the collection of information related to safety evaluation.

·        Increasing or decreasing the number of study visits, provided the decrease does not affect the collection of information related to safety evaluations;

·        Changes in remuneration;

·        Changes to improve the clarity of statements or to correct typographical errors, provided that such a change does not alter the content or intent of the statement;

·        Addition or subtraction of qualified investigators and/or study sites;

·        Minor changes specifically requested by the IBC, RSO, SCR, VA R&D or any other campus-based, University committee that has jurisdiction over research.

1.2 General Provisions

Changes in approved research, during the period for which approval has already been given, may not be initiated without prior IRB review (full, expedited review, or exempt as appropriate) and approval, except where necessary to eliminate apparent immediate hazards to human participants.

Investigators must submit requests for changes to the IRB in writing.  Upon receipt of the protocol change, the IRB Chairperson or designee will determine if the revision meets the criteria for minimal risk.  If the change represents more than a minimal risk to subjects, it must be reviewed and approved at a convened meeting of the appropriate IRB.  Minor changes, involving no more than minimal risk to the subject, will be reviewed by the expedited review procedure. (SOP 402)

Amendment requests must be submitted by completing an IRB Protocol Modification Form. Documentation should be included with the completed form indicating the requested revision(s) and must clearly outline the requested revision(s).

In evaluating the IRB Protocol Amendment Form and the documentation, the IRB chairperson or designee will consider expedited review or full Board review. Expedited review will be utilized for amendments involving minor, or minimal risk, revision(s). Full Board review will be required for any major, controversial, or questionable revision(s).

1.3 Other Criteria

The IRB may require verification of information submitted by an Investigator. The purpose of verification will be to provide necessary protection to participants when deemed appropriate by the IRB.

2.  SCOPE

These policies and procedures apply to all HRPP staff, Investigators and research staff and IRB members.

 

3. RESPONSIBILITY

 

IRB Coordinator is responsible for ensuring that the IRB Chairperson has all the tools and resources needed to complete the initial review of the Protocol Modification.

 

IRB Chairperson or designee is responsible for determining expedited review or Full Board review of the IRB Protocol Modification.

 

IRB Member (Reviewer) is responsible for presenting the Protocol Modification at the next convened meeting.

4.  APPLICABLE REGULATIONS AND GUIDELINES

45 CFR 46.109

21 CFR 56.109

5.  REFERENCES TO OTHER APPLICABLE SOPs

This SOP affects all other SOPs

6.  ATTACHMENTS

            302-C             Protocol Modification Form

7.  PROCESS OVERVIEW

7.1 IRB Coordinator initially reviews and triages the amendments for expedited review or full Board review.  IRB Coordinator forwards the IRB Protocol Modification Form and the documentation to the IRB Chairperson for expedited review.  If the IRB Coordinator is not certain if an amendment requires full Board review, the Chairperson will make that determination.

IRB Chairperson indicates expedited review by stamping and initialing the IRB Protocol Modification Form for approval, or by using the yellow note sheet to make revisions or to forward for full Board Review.

IRB Coordinator examines the IRB Protocol Modification for approval and examines the yellow note sheet for revisions or for a notation to forward for full Board Review.

In the case of expedited review, the IRB Coordinator prints the approval letter and presents it to the Chairperson for signature.

In the case of convened Board review, IRB Coordinator places the amendment on the next appropriate agenda for full Board review.

IRB Member (Reviewer) presents the IRB Modification to the full Board for discussion and approval or for revisions.

IRB Coordinator prints the appropriate letter based upon the Board action and presents it to the Chairperson for signature.

8.  PROCEDURES EMPLOYED TO IMPLEMENT THIS POLICY

Who

Task

Tool

IRB Coordinator

 

 

Make initial determination regarding amendment.

Upon completion of the review of the amendment, add amendment to the next IRB Meeting Agenda and indicate the outcome.

Protocol Modification Form

 

 

IRB Chairperson

Make final determination regarding approval of amendment, additional revisions or convened board review.

Protocol Modification Form and documentation of revision(s).

IRB Member  (Reviewer)

Present summary of findings and recommendations at the next convened IRB meeting.

Protocol Modification Form and documentation of revision(s).

 

 

 


 

SOP: 407

Version No: 1

Effective Date:  07/01/2005

UNANTICIPATED PROBLEMS AND PROTOCOL DEVIATIONS

Supercedes Document Dated: 10/15/04

 1.  POLICY

The Institutional Review Board (IRB) requires Investigators to promptly report any unanticipated problem that involves risks to participants or others.  Unanticipated problems are any unforeseen event or events that may involve risks or affect the study or welfare of participants or others, or that may affect the integrity of the research.  These events can occur in both biomedical and social/behavioral research.  Generally, the type of risks involved in these events can be physical, emotional, social, financial, or legal.  They may directly involve individuals participating in the research study or individuals indirectly involved as part of the research team, and/or affect the integrity of the study.

 

Also, the Institutional Review Board (IRB) requires Investigators to promptly report protocol deviations.  Protocol deviations are events that are a departure from the specific protocol procedures approved by the IRB.  Protocol deviations may or may not place participants at risk.

 

Specific Policies

 

1.1     Unanticipated Problems and Protocol Deviations

Unanticipated problems will be reported to the IRB by the Investigator explaining the occurrence and if applicable an explanation as to how to avoid future occurrences.  If other entities are involved, it is the responsibility of the Investigator to notify them of the occurrence. The event will be reviewed by an IRB Chairperson, sent to the convened IRB for review if deemed necessary by the IRB Chairperson, and assessed for necessary action that may need to be taken.  The range of actions may include, revisions to the protocol, audit of the research site, institution of a schedule of continuing review that is more frequent than on an annual basis or additional protective procedures requested by the IRB (i.e. observation of the informed consent process).

 

It is within the authority of the IRB to institute IRB site visits to ensure investigator/clinical team integrity if the IRB receives an excessive number of unanticipated problems, protocol deviations, or if the IRB suspects noncompliance or improprieties on the part of the Investigator and/or clinical team.

 

 

 

Examples of Unanticipated Problems:

·        An injury to a research staff member while conducting study related procedures (i.e. research coordinator inadvertently exposed to a low level of radiation during a study)

·        Loss of a participant’s research records that contain private health information, which poses a breach of confidentiality. 

 

Examples of Protocol Deviations:

 

·        Participants who have been enrolled in a research project but failed to meet all of the inclusion criteria.

 

·        Participants who sign an outdated or unapproved version of the informed consent document. 

 

·         Participants who are seen outside of the timeframe as specified by the protocol.

 

·         Incorrect dosage of the drug administered to the participant.

 

2.  SCOPE

These policies and procedures apply to all research submitted to the IRB.

3.  RESPONSIBILITY

Investigators involved in human participant research will report all unanticipated problems.

IRB Chairpersons are responsible to review reports and forward to the convened IRB when appropriate.

     

4.  APPLICABLE REGULATIONS AND GUIDELINES

45 CFR 46.103,109

21 CFR 56.108, 109

5.  REFERENCES TO OTHER APPLICABLE SOPs

This SOP affects all other SOPs

6.  ATTACHMENTS

      407-A       Unanticipated Problem Report Form

      407-A-1   IRB Form For Reporting Unanticipated Problems in Human      

                      Subjects

      407-B       Protocol Deviation Report Form

7.  PROCESS OVERVIEW

7.1             Reporting Requirements for Unanticipated Problems

Unanticipated problems that occur during the course of a research study must be submitted to the IRB using the appropriate form for each campus.  Information will include a summary of the problem or incident and a description of the corrective action that will be taken to alleviate a future occurrence of the problem. 

 

In cases where a modification to the protocol is necessary to correct the deviation, a protocol modification form should also be submitted to the IRB for review and approval.

 

7.2       The HRPP and IRB staff, and IRB members will immediately report to the HRPP Director unanticipated problems.  The HRPP Director communicates this information to the appropriate IRB Chairperson, Director of Compliance.  An audit is conducted and results reported to all parties.  The IRB makes recommendations for corrective action.  Members of the audit team conduct a follow up meeting to assure corrective actions are completed.

 

The HRPP Director will report to OHRP, FDA and the sponsor as appropriate.  The HRPP Director provides follow up information when necessary or as requested by OHRP and FDA.

 

 

7.3       Review Procedures for Unanticipated Problems

The IRB Chairperson will initially review unanticipated problems on an expedited basis. The IRB Chairperson will either approve the information submitted or request revision or additional information from the Investigator. 

 

If the IRB Chairperson determines that convened IRB review is appropriate, the item will be placed on the next meeting agenda for convened Board review. The IRB will either approve the item as presented or request revision or additional information from the Investigator.

8.  PROCEDURES EMPLOYED TO IMPLEMENT THIS POLICY

Who

Task

Tool

IRB Coordinator

Collects unanticipated problem reports from IRB in-box and enters them into the IRB database.

Forwards reports to appropriate IRB Chairperson for review.

Communicates IRB Chairperson’s requests for additional information back to the Investigator

Upon request by the IRB Chairperson, posts the item to the next IRB meeting agenda for convened IRB Board review.

Following convened Board review, communicates to the Investigator the status of the submitted information regarding the unanticipated problem and any other requests for additional information or action that should be taken.

IRB Database

 

 

 

 

 

IRB Database

 

 

Contingent Approval Letter or Approval Letter

 


 

SOP: 408

Version No: 1

Effective Date: 07/01/2005

Study completion

Supercedes Document Dated: 10/15/04

1.  POLICY

The completion or termination of a study is a change in activity and therefore must be reported to the IRB. A notice of closure to the IRB is used by the IRB to close its files but more importantly to provide pertinent information to the IRB in its evaluation and approval of related studies.  Completion or termination of a study may be reported to the IRB on a Final Closure Report or the Application for Continuing Review. 

Specific Policies

1.1  Determining When a Project May be Closed

A.     Investigator initiated protocols may be closed when individually identifiable follow-up data are no longer being collected on participants and analysis that could indicate new information has been completed.

B.  Multi-site industry studies may be closed when the Investigator submits his/her final report.

1.2  Final Closure Reports Defined

A.     Final Closure Reports

Final closure reports should be submitted within thirty (30) days after completion or termination of the study. The IRB Chairperson will review all reports of study completion and, if needed, request further information from the Investigator to clarify any questions that may arise.

B.     Continuing Reviews Submitted as Final Closure Reports

The continuing review form may also represent an avenue for final closure.  This form requests specific information from the investigator and should be submitted accordingly.

2.  SCOPE

These policies and procedures apply to all research submitted to the IRB.

3.  RESPONSIBILITY

IRB Coordinator is responsible for ensuring all study completion documentation is received, reviewed, presented to the IRB, and filed appropriately.

4.  APPLICABLE REGULATIONS AND GUIDELINES

21 CFR 56.108, 56.109

45 CFR 46.103, 46.109

5.  REFERENCES TO OTHER APPLICABLE SOPs

This SOP affects all other SOPs.

6.  ATTACHMENTS

302-B Application for Continuing Review 

302-F Final Closure Report

7.            PROCESS OVERVIEW

7.1.         Convened Board and Expedited Projects

7.1.1.     The Final Closure Report is accepted by the IRB during mid-cycle of the project.  An Application for Continuing Review is accepted during the anniversary period at the time the study must receive continuing review and re-approval from the IRB.  These reports are processed similarly in the IRB.

7.1.2.     Final Closure Reports will be submitted to the IRB by the Investigator within 30 days after completion or termination of the study.  The IRB coordinator will review all reports of study completion and, if needed, request further information from the Investigator to obtain missing data or to clarify any questions that may arise. 

7.1.2  The final closure report will then be reviewed and approved for     closure by the IRB Chairperson.  The IRB Coordinator will change the study status in the IRB database and update the next meeting agenda to reflect the study closure. 

7.1.3       The IRB coordinator will generate a final closure letter and present it to the IRB Chairperson for signature.  The IRB Coordinator will send the letter to the Investigator and file the final closure report and a copy of the final closure letter in the study file. 

7.1.4       The file will be stamped with the inactivated date on the front cover  and filed in a separate area for inactivated study files.

7.2    Exempt Studies

7.2.1 Once each year the IRB will send the Investigator the Protocol Exempt Status letter.  The Investigator will indicate on the letter if the study is currently active or has been terminated and return the letter to the IRB.

7.2.2       Upon receipt of the letter from the Investigator, the IRB will process the letter based upon the response given.  If the Investigator indicates the study is active the letter is filed in the study file.

7.2.3       If the Investigator indicates the study has been terminated the letter will be presented to the Chairperson for approval.  The termination will be recorded in the next appropriate agenda/minutes for reporting to the IRB.


8.  PROCEDURES EMPLOYED TO IMPLEMENT THIS POLICY

Who

Task

Tool

HRPP Assistant Director

Instruct Investigators to submit a Final Closure Report upon completion of the study, in the form of either a completed Application for Continuing Review Report or a Final Closure Report. 

Application for Continuing Review Report Final Closure Report

Exempt Study Status Letter

Staff Assistant

For exempt studies, a form letter is sent yearly to the Investigator requesting the status of the study.

Protocol Exempt letter

IRB Coordinator

 

 

IRB Chairperson

 

 

IRB Coordinator

Review Final Closure Report and obtain any outstanding information or documentation from the Investigator to close the study.  If there are inconsistencies or if clarification is needed, request additional information.

If the study may be closed and the contents of the IRB file are complete, authorize closure of the study.

Add the study to the next appropriate agenda for presentation to the IRB at its next convened meeting.

 

IRB Coordinator

Follow-up per instructions of the IRB Chairperson. 

If study can be closed, send Completion Acknowledgement, attached.

 

Completion Acknowledgement

 

 


 

SOP: 409

Version No: 1

Effective Date: 07/01/2005

Categories of Action

Supercedes Document Dated: 10/15/04

1.  POLICY

As a result of its review, the IRB may decide to approve or disapprove the proposed research activity, or to specify modifications required to secure IRB approval of the research activity. Except when the expedited review procedure is used, these actions will be taken by a vote of a majority of the regular and alternate members present, except for those members present but unable to vote in accordance with IRB's conflict of interest policies.  When reviewed via expedited review, the IRB Chairperson or designee can take any of the following actions except to disapprove a study.

Specific Policies

1.1 Determinations

The IRB may make one of the following determinations as a result of its review of research submitted for initial review or for continuing review:

A.     Approval: The protocol and accompanying documents are approved as submitted. Final approval will commence on the day the study is approved by an action of the convened IRB or IRB Chairperson or designee and expire within one (1) year of the meeting date that the project was approved or contingently approved.

The conditions for continued approval, and the time frame (if any) within which they must be met will be clearly stated in the approval letter.  If the conditions of the approval are not met, approval may be withdrawn.

B. Contingent Approval: Specific modification of a protocol or accompanying document(s) is required.  Changes will be voted upon during IRB’s meeting, as well as the terms of approval. Such specific changes must be clearly outlined by the IRB. The Investigator will be informed in writing of the required changes and requested information and must provide the IRB with the changes or information.

The IRB Chairperson or his/her designee has the authority to review the information via expedited review unless the IRB requires or the IRB Chairperson decides that the material or information be reviewed by the convened IRB, the primary reviewer or another individual delegated by the IRB to review the response.  Upon satisfactory review, approval will be issued as of the date that the requested information or materials are approved.  However, the expiration date of IRB approval will be based on the anniversary date of the initial IRB review.  Participants must not be recruited into the study until final approval has been issued.

C. Deferral: Significant questions are raised by the proposal or the information provided is inadequate to assess risk/benefit ratio requiring its reconsideration by the convened IRB after additional substantive information is received from the Investigator and/or Sponsor. The Investigator will be informed in writing of the IRBs concerns and requested information and be given the opportunity to respond to the IRB with the changes or information.

D. Disapproval: The proposal fails to meet one or more criteria used by the IRB for approval of research. Disapproval cannot be given through the expedited review mechanism and may only be given by majority vote at a convened meeting of the IRB.  The Investigator will be informed in writing of the IRBs concerns and requested information and be given the opportunity to respond to the IRB. Disapproval of a study by the IRB cannot be overturned by the University administration.

 

 

2.  SCOPE

These policies and procedures apply to all research submitted to the IRB.

3.  RESPONSIBILITY

IRB Chairpersons and HRPP Director is responsible for ensuring that all IRB decisions and actions are based on institutional and regulatory requirements.

IRB Chairpersons are responsible for ensuring the appropriateness of all IRB decisions and actions.

4.  APPLICABLE REGULATIONS AND GUIDELINES

21 CFR 56.109, 56.111, 56.113

45 CFR 46.109

5.  REFERENCES TO OTHER APPLICABLE SOPs

This SOP affects all other SOPs.

6.  ATTACHMENTS

None

 

7.  PROCESS OVERVIEW

7.1.1 As a result of its review of research submitted for initial or continuing review, the IRB may decide to approve, disapprove, or defer the proposed research activity, or to contingently approve by specifying modifications required to secure IRB approval of the research activity.  These actions will be taken by a vote of a majority of the regular and alternate members present except for those members who have recused themselves in accordance with IRB's conflict of interest policies.  

7.1.2 When reviewed via expedited review, the IRB Chairperson or designee can take any of the following actions except to disapprove a study.

7.1.3 At the time the motions are made during the convened IRB meeting, the IRB Coordinator records the determinations made utilizing the IRB database.  In addition to recording the determinations noted below the IRB Coordinator will record in the IRB database the voting results, including number for and against; names of members making the motions, the name of any members abstaining.

7.1.4 Approval: The protocol and accompanying documents are approved by the convened IRB as submitted with no changes. Approved by Board is the motion designated by the IRB Coordinator in the IRB database for Approval. 

The protocol and accompanying documents are approved under expedited review by the IRB Chairperson as submitted with no changes.  Approved by the Chair is the motion recorded by the IRB Coordinator in the IRB database for approval. 

Final approval will commence on the day the study is approved by an action of the convened IRB or IRB Chairperson or designee and expire within one (1) year of the meeting date, but not later than the day preceding the date of review.  The research may proceed as soon as the Investigator receives the IRB approval letter for the study.  The IRB Coordinator is responsible for recording the approval date and expiration date in the IRB database and for generating an approval letter.

7.1.5 Contingent Approval: The protocol and accompanying document(s) are determined by the convened IRB to be approval with minor changes required.  The required minor changes may be reviewed under expedited review by a designated reviewer. 

The minor changes must be specific and clearly delineated by the IRB.  The minor changes and terms of approval will be voted upon during the convened IRB meeting. The motion of contingent approval is recorded by the IRB Coordinator in the IRB database as Contingently Approved by Board. The IRB Coordinator is responsible for recording the contingent approval date and for generating a contingent approval letter. 

The IRB Chairperson or his/her designee has the authority to review the information via expedited review unless the IRB requires that the material or information be reviewed by the full IRB, the primary reviewer or another individual delegated by the IRB to review the response. 

The board requested information received from the Investigator must provide the IRB with all of the required changes or information in order for final approval to be granted.  Upon satisfactory review, final approval will be issued as of the date that the requested information or materials are approved.  However, the expiration date of IRB approval will be based on the anniversary date of the initial IRB review.  Subjects must not be recruited into the study until final approval has been issued.

For studies reviewed and given contingent approval by the IRB Chairperson under expedited review criteria, the IRB Chairperson will note the requested changes in the file.  The IRB Coordinator will delineate in writing the minor changes requested by the IRB Chairperson.  Upon satisfactory review, final approval will be issued as of the date that the requested information or materials are approved.  Approved by the Chair is the motion recorded by the IRB Coordinator in the IRB database for approval. 

An Investigator is given 60 days to respond to the IRB.  If the requested information is not received, the project will be withdrawn by the IRB.

7.1.6 Deferral: A motion of deferral is made when significant questions are raised by the IRB concerning the protocol, pending receipt of substantive information from the Investigator and/or sponsor. The motion of deferral is designated in the IRB database as Deferred by Board.   The IRB Coordinator is responsible for recording the Deferral Date in the database.  The IRB Chairperson is responsible for promptly contacting the Investigator and for drafting the deferral letter for the IRB Coordinator. 

An Investigator is given 60 days to respond to the IRB.  If the requested information is not received, the protocol will be withdrawn by the IRB.

7.1.7       Disapproval:  A motion of Disapproval is made by the convened IRB when the protocol fails to meet one or more criteria used by the IRB for approval of research.  Disapproval cannot be given through the expedited review mechanism and may only be given by majority vote at a convened meeting of the IRB.

            The motion of disapproval is designated in the IRB database as Disapproved by Board.  The IRB Coordinator is responsible for recording the Date of Disapproval in the database.  The IRB Chairperson is responsible for promptly contacting the Investigator and for drafting the disapproval letter for the IRB Coordinator.    


 

8.  PROCEDURES EMPLOYED TO IMPLEMENT THIS POLICY

Who

Task

Tool

IRB Coordinator

Document IRB decisions in the minutes.

Review pending items weekly and communicate to Investigators and Research Staff, the requests of the IRB

IRB Minutes

Email

IRB Chairperson (or designee)

Review and sign all IRB decision letters.

 

IRB Coordinator

Distribute IRB decisions/letters in a timely manner.

See SOP 601

 


 

 

SOP: 410

Version No:

Effective Date: 07/01/2005

 

study recruitment
and Advertisements

Supercedes Document Dated: 10/15/04

1.      POLICY 

Generally, the IRB discourages Investigators from enrolling themselves, his/her students, or his/her employees in the Investigator’s own studies, but will review the matter on a case-by-case basis.  The IRB will consider the degree of risk, likelihood of benefit, and protections from coercion or undue influence in deciding whether to allow such recruitment.  Recruitment of the Investigator, his/her students, or his/her employees is not allowed unless specifically approved by the IRB.

 

The IRB does not allow bonus payments to Investigators or study personnel as incentives for participant recruitment.

 

Potential research participants may be identified through any of the following methods: 

 

Private Medical Information:  A common method of identifying potential research participants is to review medical records, clinical databases, patient registries, and psychosocial screening databases.  This method allows the Investigator to review records and identify eligible participants.  The IRB/Privacy Board must review and approve all such methods of obtaining private medical information prior to initiation.

 

Referring Physicians:  Referrals from treating physicians can be useful in identifying potential trial participants. Referring physicians who have been provided with general information about a research project may inform their patients that a research project is available and provide the patients with contact information to learn more about the project and whether they might be eligible. 

 

Advertisements:  The IRB and the FDA considers direct advertising for study participants to be the start of the informed consent and participant selection process.  Direct advertising for research participants, (i.e. advertising that is intended to be seen or heard by prospective participants to solicit their participation in a study), is not in and of itself, an objectionable practice. 

 

Direct advertisements that are intended for prospective participants include, but are not necessarily limited to the following:

o       Newspaper

o       Radio

o       TV

o       Bulletin boards

o       Posters

o       Flyers

o       Emails

 

Direct advertisements do not include: participant or Investigator interviews, communications intended to be seen or heard by health professionals, such as ‘Dear Doctor’ letters (or communication with other types of practitioners for the purpose of soliciting assistance in identifying research participants), and doctor-to-doctor letters (even when soliciting for study participants), news stories or publicity intended for other audiences such as financial page advertisements directed toward prospective investors.

 

Direct advertisements must be reviewed and approved by the IRB as part of the package for initial review. 

 

In a limited number of circumstances, advertisements pertaining to human participant research being conducted by OU faculty may also be reviewed by the Office of Public Affairs (PA).

 

Specific Policies

1.1      IRB Review of Study Recruitment Methods and Advertisements

1.1.1  The IRB review must review study recruitment methods and advertisements prior to their use by the researcher, usually as part of the initial review and approval of the research project.  It is the responsibility of the Investigator to include recruitment methods in the IRB application and submit the proposed advertisements at the time of the initial submission or as a modification of an approved protocol.  All such documents must be reviewed and approved prior to use in the recruiting process. 

 

1.1.2  The IRB must review direct advertising to assure that it is not unduly coercive and doesn’t overstate the potential benefits of the research beyond what is outlined in the consent and the protocol.  This is especially critical when a study may involve participants who are likely to be vulnerable to undue influence.  Advertisements should be limited to the information necessary for potential participants to make an informed decision. 

 

1.1.3  When direct advertisements are not included in the initial project plan and are not submitted to the IRB at the time of initial submission, but the Investigator later decides to advertise for participants, the direct advertisements must be submitted to the IRB as an amendment to the ongoing research project. 

 

1.2     Advertisements to recruit participants should be limited to:

1.2.1       The individual name or specific office or department and the accurate address and telephone number of the Principal Investigator as well as the location of the research and the person to contact for further information;

1.2.2       Wording that effectively communicates the purpose of the research, and in summary form the eligibility criteria that will be used to admit participants into the study; and

1.2.3       A straight-forward and truthful description of the benefits (payments or free treatment is not to be overstated or the main focus) to the subject from participation in the study and the duration of the study and treatment.

1.2.4       When appropriately worded, the following items may be included in advertisements. 

a.      The name and address of the principal investigator and/or research facility;

b.      The condition under study and/or the purpose of the research;

c.      In summary form, the criteria that will be used to determine eligibility for the study;

d.      A brief list of participation benefits, if any;

e.      The time or other commitment required of the participants; and

f.        The location of the research and the person or office to contact for further information.

 

1.3     Advertisements to recruit participants should not:

1.3.1       Mislead participants;

1.3.2       Claim, either explicitly or implicitly, that the drug or device is safe or effective for the purpose under investigation, or that the drug or device is in any way equivalent or superior to any other drug or device;

1.3.3       Imply the research or investigator has a unique or special skill, remedy or treatment;

1.3.4       Should not promise “free medical treatment,” when the intent is only to say participants will not be charged for taking part in the investigation.  Advertisements may state that participants will be paid, but should not emphasize the payment or the amount to be paid, by such means as larger or bold type.

1.3.5       Include monetary amounts as rewards or inducements to participate (it may, however, mention there will be compensation for the participant’s time or travel).

 

1.4     E-mail Distribution List Advertisements

                  Oklahoma City Campus IRB only:

Advertisements in which the Investigator wishes to utilize campus-wide e-mail distribution list will adhere to the following guidelines:

 

1.4.1       The IRB number should be located in the lower left corner of the recruitment notice.

1.4.2       Graphics may not be included.

1.4.3       The Investigator should include a description of the study for the email subject line of the recruitment notice.

1.4.4       The Investigator should include on the Protocol Modification Form which groups should receive this recruitment notice (faculty, staff, and /or students).

1.4.5       The Investigator should provide a name and e-mail address of the person(s) to whom potential participants may respond.

1.4.6       The Investigator shall submit a Protocol Modification form with the proposed e-mail recruitment notice to the IRB.  The recruitment notice should appear exactly how it will appear in the e-mail.

1.4.7       The IRB staff is authorized to forward e-mail to the distribution list moderators.  Norman Campus IRB Investigators submit directly to the distribution list moderator.

1.4.8       Internet Advertising-The Investigator initiates the posting of a study on the internet-this type of advertising requires prior IRB review and approval.

1.4.9       The sponsor initiates the posting of the study on the internet- this type of advertising does not require IRB approval.

 

 

1.5   All Advertisements

All advertisements should contain a statement that the University of Oklahoma is an equal opportunity institution.

2.  SCOPE

These policies and procedures apply to all advertisements that pertain to human participant research.

3.  RESPONSIBILITY

The IRB will be responsible for reviewing recruitment methods and all direct advertisements submitted by the Investigator that pertains to research projects involving human participants.

 

The Oklahoma City Campus IRB will be responsible for submitting approved e-mail ads to the OUHSC Distribution List Moderator.

4.  APPLICABLE REGULATIONS AND GUIDELINES

45 CFR 46.

21 CFR 56.

FDA Information Sheets-Guidance for Institutional Review Boards and Clinical Investigators-Recruiting Study Subjects 1998 Update

5.  REFERENCES TO OTHER APPLICABLE SOPs

This SOP affects all other SOPs.

6.  attachments

410-A INFORMATION SHEETS-Guidance for Institutional Review Boards and Clinical Investigators 1998 Update.

7.  process overview

Norman Campus IRB:

All advertisements will be submitted to the Norman Campus IRB for review and approval prior to submission to PA. This pertains to advertisements that will be distributed off campus as well as on campus. After receipt of advertisements from the Investigator, the IRB staff will obtain IRB approval before submitting advertisements to PA; investigators must not submit advertisements directly to the PA Office.

 

OUHSC Campus IRB:

In rare circumstances, recruitment/advertising materials will require Public Affairs review (e.g. participant interviews for advertising purposes).  These types of recruitment/advertising methodologies will be forwarded to PA by the OUHSC IRB staff.  After review of the materials by PA (and the required revisions received from the PI), the items will be sent to the Chair for review and approval.

 

7.1 For details regarding interaction with PA and the advertisement approval process, refer to SOP 602E Public Affairs.

 

7.1.1       Advertisements received with the initial submission of full board studies will be reviewed by the convened IRB. 

7.1.2       Advertisements received with the initial submission that meet the criteria for expedited review will be reviewed by the IRB Chairperson. 

7.1.3       The IRB Chairperson will review advertisements received as an amendment to an ongoing research project.

8.  PROCEDURES EMPLOYED TO IMPLEMENT THIS POLICY

Who

Task

Tool

IRB Coordinator

Reviews new study submission and amendments for inclusion of an advertisement.

Forwards most advertising to IRB Chair for review and approval.

Requests changes from PI, per IRB Chair direction.

In rare circumstances, will forward a copy of the advertisement to the Office of Public Affairs for review,

If Public Affairs requests revision, the IRB Coordinator will forward the changes to the Investigator for completion.  The revised advertisement will then be forwarded to the IRB Chairperson or convened committee for review.

Forwards the approved email ad to the DLM.

Print a copy of the email ad that was distributed to file in the IRB file.

New Study Checklist

 

 

 

 

 

FAX

 

 

 

 

 

 

E-mail

IRB Chairperson

Review materials per SOP Section 400, as appropriate.