Wayne State University

Exempt Research

Below is a description of research projects at Wayne State University that may qualify for exemption from review by the full Institutional Review Boards for medical and behavioral research.

If an investigator believes that his/her project qualifies for exemption, he/she should submit one copy of the completed signed Medical or Behavioral Protocol Summary Form and one copy of the original research protocol. A designated member of the IRB must "concur" that the project qualifies for exemption. An investigator cannot exempt him/herself. Exemptions and/or expedited approvals may not be requested in person or by telephone. A research project cannot start until after the "concurrence" by a designated member of the IRB or review by one of the Institutional Review Boards. Retroactive "concurrence" or review cannot occur.

Exemption Categories

Unless otherwise required by department or agency heads, research activities in which the only involvement of human research participants will be in one or more of the following categories are exempt from review by the WSU Institutional Review Board:

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

  1. research on regular and special education instructional strategies, or
  2. research on the effectiveness of or the comparison among instructional techniques, curricula, or classroom management methods.

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

  1. information obtained is recorded in such a manner that human subjects can be identified, directly or through identifiers linked to the subjects; and
  2. 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.

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 under paragraph 2 above, if:

  1. the human subjects are elected or appointed public officials or candidates for public office; or
  2. Federal statute(s) require(s) without exception that the confidentiality of the personally identifiable information will be maintained throughout the research and thereafter.

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 subjects.
(Note: To qualify for this exemption the data, documents, records, or specimens must be in existence before the project begins.)

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:

  1. public benefit or service programs, or
  2. procedures for obtaining benefits or services under those programs, or
  3. possible changes in or alternatives to those programs or procedures,
  4. possible changes in methods or levels of payment for benefits or services under those programs.

6. Taste and food quality evaluation and consumer acceptance studies if:

  1. wholesome foods without additives are consumed or
  2. 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 Food and Drug Administration or approved by the Environmental Protection Agency or the Food Safety and Inspection Service of the U.S. Department of Agriculture.

7. (WSU IRB Exempt Category 7) Research with adults and/or minors involving the use of educational tests (cognitive, diagnostic, aptitude, achievement), survey procedures, interview procedures, behavioral games, tasks or observation of public behavior, unless:

  1. information obtained is recorded in such manner that human participants can be identified, directly or through identifiers linked to the subjects; and
  2. any disclosure of the human subjects' responses outside the research could reasonably place the participants at risk of criminal or civil liability or be damaging to the subjects' financial standing, employability, or reputation.

8. (WSU IRB Exempt Category 8) Research involving no direct interaction or intervention with human participants that is limited to the study of identifiable data and it is not feasible to obtain consent from participants.  If Protected Health Information (PHI) will be used, a HIPAA Waiver of Authorization is still required.