In addition to the formal comments from the National Coalition for History, endorsed by other scholarly associations, individual historians have begun submitting comments on the notice of proposed rulemaking. Without exception, they endorse the proposal to free oral history from IRB review. The only opposition comes from a professor of education and psychology who seems to suggest that tribal governments should hold veto power over oral history research.
Here are some of the highlights, alphabetical by last name. I have edited some for brevity. Full comments can be found at http://www.regulations.gov/#!documentDetail;D=HHS-OPHS–2015–0008–0001
“My mother is 77 years old and lives with me. Yet campus IRB required me to get their permission to talk to her about the project (which included asking her questions as I went through church records). If that doesn’t indicate the idiocy of requiring IRB approval for history research projects, I don’t know what does.”
“The requirements for IRB review at my university have been taken to include student research, even that conducted in undergraduate classes. To avoid the paperwork, I do not give my students oral history interview assignments, even simple ones like interviewing relatives about their experiences during historical events. Another faculty member has told me that she restricts her students to interviewing one another when training them in oral history techniques. Graduate students are reluctant to include oral history interviews in their thesis research due to the time constraints imposed by the requirement of applying to the IRB.
“For historical scholars like myself, the difficulty lies in translating our research and goals into the mindset of the IRB forms and regulations.
The views, opinions and positions expressed by these authors and blogs are theirs and do not necessarily represent that of the Bioethics Research Library and Kennedy Institute of Ethics or Georgetown University.