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SRC/IRB
review of the Research Plan is required prior to experimentation for
ALL projects involving human subjects except those specifically noted
below.
The
Metro Richmond Science Fair rules regarding human subjects in experimentation
follow ISEF guidelines and those of the federal government. The rules
exist to protect the rights and welfare of individuals who participate
as research subjects and to protect the student researcher. When students
use human subjects, they are directly responsible for ensuring the rights
and welfare of those subjects. (If in doubt about any regulations, consult
the Belmont Report and CFR Title 45 Part 46.)
In
general, if a student interacts or intervenes with a human to collect
data or collects identifiable private information then
that project must be reviewed and receive official approval before the
experiment may be started. All students conducting human subject
research projects, including surveys, professional tests, questionnaires,
and studies in which the student is the subject of his/her own research,
must submit a research proposal to the SRC/IRB
and have it approved before beginning research. Many
Human Subjects projects also require that a student obtain written consent
from the subjects before they participate in the experiment.
ALL
human subjects must have the opportunity to give their voluntary and
informed consent/assent to participate in an experiment. In order
to do this they must be aware of EVERYTHING they will
be expected to do, including any risks involved. This consent/assent
may be verbal or written depending on the amount of risk involved in
the project. It is VERY important that all subjects
know that their participation in the experiment is completely voluntary
and that they are free to stop at any time without penalty.
Exempt
Projects
Experiments
involving humans that DO NOT require
prior SRC/IRB approval or human subject paperwork
These projects are not considered restricted human
subject projects as long as they meet the following criteria.
-
the testing of student inventions, usually for engineering projects,
computer programs, etc., that
meets the following requirements:
- does
not pose a health hazard to the person testing the invention
- does
not collect or use any personal data from the "tester"
- feedback
received is in direct reference to the product
- includes
Form 3 (Risk Assessment) if teacher or SRC requires due to nature
of testing (all testing of this type should be supervised by
an adult)
- publicly
available internet or published data, such as sports statistics,
health statistics, etc.
-
data sets or records from which all personally identifiable information
has been removed before being seen by the researcher (must include
written documentation from the person supplying
the data which states that the records were de-identified),
-
behavioral observations if the researcher:
- does
not interact with the subjects in any way,
- does
not change or manipulate the environment in any way,
AND
- does
not record any information or data which could be used to identify
the subject.
Restricted
Human Subject Projects
Projects
involving humans that DO require prior
SRC/IRB approval and human subject paperwork
SRC/IRB approval needed if they involve any of the following:
- people
engaging in any physical activity, including exercise, eating or
tasting anything, medical procedures, etc.
- surveys,
questionnaires, educational testing, psychological testing, personal
opinion, etc.
- studies
using the researcher as the subject of the experiment
- viewing
records or data sets which include identifiable information (requires
a Qualified Scientist and written informed consent from
subjects)
- behavioral
observations if the researcher:
- interacts
with the subjects or modifies the environment
in any way (e.g., posting a sign),
- conducts
the experiment in a non public area, such as a day care or nursing
home,
- uses
any information that would identify the subject.
Rules
for Restricted Human Subjects Projects
- Students
using human subjects in any project must have their research plan
approved by an SRC/IRB before they begin their experiment phase.
The following must be included with a Research Proposal which is
submitted for approval:
-
Form 1
- Form
1A
-
a
written, complete research plan that includes
ALL
of the information outlined in the human subject portion
of the Research Plan Instructions (found with Form 1A)
-
Form 1B
-
Form 4 (Human Subjects Form) with all of
the items in the top section completed
-
a completed sample of the Informed Consent Form
that will be used if needed (do
not include signatures)
-
any other forms that may apply to the project (Form 2, Form
7, etc.)
-
a
copy of any survey, questionnaire
or pictures that are used in the experiment
-
The Human Subjects Form (Form
4), in conjunction with the Informed Consent Form, is designed
to be used as a Risk Assessment for projects using human subjects.
There are almost always risks involved when using human subjects
and your subjects MUST be informed of those risks in advance, on
an Informed Consent Form. For more complete information on
assessing and minimizing the risks to human subjects see the MRSF
Risk Assessment for Human Subjects or the ISEF Risk
Assessment Guide. The
SRC/IRB will make the final determination of the risk level and
will sign Form 4 in the appropriate area.
- All human subjects
must give their verbal permission to participate in an experiment
after reading an Informed Consent Form. In many cases, it
will be necessary for students to obtain written permission from
their subjects as well. This occurs if their projects are
considered by the SRC/IRB to pose more than minimal risk to the
subjects, such as eating, drinking or smelling substances or physical
exercise.
If a subject is under 18 they can only give their "assent".
It will then be necessary for a parent or guardian to give their
"consent" in addition to the "assent" of the
subject. This must be done by using an Informed Consent Form.
Students may use the online Sample
Informed Consent Form, or they can create their
own, making sure to include ALL
of the information that is on the sample. For more information
on consent procedures see Informed
Consent.
- Any survey
or questionnaire that will be used in
a project MUST be
approved by the classroom teacher and then must be submitted with
the Research Proposal to the SRC/IRB. Both the subject and,
if under 18, the parent/guardian must see and approve it
as well.
-
If music, pictures, video games or videos are used
in a project then these MUST
be viewed and approved by the classroom teacher and be made available
to the SRC/IRB if requested. Pictures must be sent with the
proposal for SRC/IRB approval. The consent form should describe
the media, including any "ratings" such as "PG".
The parents or guardians of subjects under 18 must also have the
opportunity to approve the media being used. All media must
be age appropriate and use appropriate language and images.
See the ISEF
Risk Assessment Guide
for more complete information.
- Physical
activity can be very risky for one person and of minimal
risk for another. Therefore it is necessary to identify the
subjects being used in the research plan. If a student researcher
is asking subjects to run a mile, it's important for the SRC/IRB
to know the general physical condition of the people running.
Subjects who run a mile on a regular basis, such as members of a
sports team or students who run regularly in gym class, are not
as much at risk as people in their 60's who rarely exercise.
The selection of subjects can dramatically change the risk level
of the project.
- Collecting
data from human subjects without using any names or identifying
information greatly reduces some of the risks involved in research.
All data should remain anonymous (including to the student researcher)
in as many projects as possible. This is especially true if
the student is collecting information on grades, IQ's, or SAT scores,
etc. It is helpful for the SRC/IRB to know how students are
collecting their data and if the information will be kept anonymous.
- It
is required that students work with a Qualified Scientist if their
research involves more that minimal risk to their subjects.
This includes, among others, some forms of exercise and any experiment
which requires subjects to eat, drink
or smell something out of the ordinary. Foods
or drinks that are commonly available in this area, or some physical
activities may be considered minimal risk by the SRC/IRB.
Therefore, it is important to include precise information on the
foods or activities in the research plan so that the review board
may make an informed decision.
The school nurse may act as the Qualified Scientist if she/he is
an R.N. and is approved by the SRC/IRB. If the Qualified Scientist
is unable to directly oversee the activity, then a Designated
Supervisor must be appointed (teacher or other adult) and
trained. In this case, the Qualified Scientist would fill out the
Qualified Scientist Form (Form 2) and the Designated
Supervisor would sign the box at the bottom of the form. See Risk
Assessment for Human Subjects
for additional information.
- If
the student is planning to conduct human subject research in a federally
registered research institution (university lab, etc.) then the
project must be reviewed and approved by that institution’s IRB.
Documentation stating that the student’s particular work
was officially approved (the project must be identified in the research
plan) must be included in the submission of the project to the Fair.
A letter from the mentor is not sufficient. If a student is unable
to obtain documentation of official approval from the institution
then the project must be reviewed and approved by the Fair SRC/IRB.
- The
practice of medicine by students is illegal and is not permitted.
With documentation of direct and complete supervision by a licensed
professional (Qualified Scientist), students may observe and collect
data for analysis of new procedures and medications. Students
are not allowed to administer medications to or perform invasive
medical procedures on human subjects.
- It
is illegal to publish or display information, including photographs,
that could directly or indirectly identify any human subject without
written consent from the subject (and the parent/guardian if the
subject is under 18). The ISEF Sample Informed
Consent Form does not have a statement giving permission to use
data or photos of a subject and therefore cannot be used in this
way. Student researcher must develop their own permission
form to use in these cases and they must be signed by the subject
and the parent/guardian if the subject is under 18.
This signed form must be available for inspection by the safety
committee at the Fair set up.
- All
standardized tests that are not in the public domain
must be administered, scored and interpreted by a Qualified Scientist
as required by the test publisher. Any use of this type of test
must follow the guidelines set by the publisher, including obtaining
copies of the test. Results
of testing should never be divulged by a student researcher to
the subjects and tests should be conducted as anonymously as possible.
- Students
may use the internet and email to collect data for human subject
projects, but this type of data collection is challenging. It is
difficult to make sure that your subjects are of the proper age
or are not returning multiple responses. It is also difficult
to collect anonymous data or to obtain Informed Consent. The
responses may need to be channeled through a Qualified Scientist,
such as a school counselor, who will then collect the data and de-identify
the people sending it. The
Intel ISEF has a more detailed discussion of the use of internet
surveys and has developed some guidelines on obtaining Informed
Consent in their Risk
Assessment Guide.
Links to Additional Rules and
Information
Risk Assessment for Human Subjects
Informed
Consent
Intel
ISEF Risk Assessment Guide for Human Subjects
This guide gives some specific examples of projects
to help students determine risk.
Sources
of Additional Information
Belmont Report, April 18, 1979
http://ohsr.od.nih.gov/guidelines/belmont.html
OPRP
– NIH, Institutional Review Board
(IRB) Guidebook
R.
I. Penslar
http://www.hhs.gov/ohrp/irb/irb_guidebook.htm
Standards
for Educational and Psychological Testing
http://www.apa.org/science/programs/testing/standards.aspx
American
Psychological Association Information for students:
http://www.apa.org/science/leadership/students/information.aspx
Educational
and Psychological Testing
Testing Office for the APA Science Directorate
http://www.apa.org/science/programs/testing/index.aspx
See
the ISEF website for additional resources.
http://www.societyforscience.org/Page.aspx?pid=317
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Updated
9/14/10 |