WEBSTER UNIVERSITY
INSTITUTIONAL REVIEW BOARD
(IRB)
THE IRB PROCESS
3. Examine Helpful Tips To Ensure
A
Smooth Approval Process
Tips Towards
Obtaining
Consent
The following comments may help in the development of an approach and
proposed language by investigators for obtaining consent and its
approval
by the IRB:
-
Informed consent is a process, not just a form. Information must be
presented
to enable persons to voluntarily decide whether or not to participate
as
a research subject. It is a fundamental mechanism to ensure respect for
persons through provision of thoughtful consent for a voluntary act.
-
The procedures used in obtaining informed consent should be designed to
educate the subject population in terms that they can understand.
Therefore,
informed consent language and its documentation (especially explanation
of the study's purpose, duration, experimental procedures,
alternatives,
risks, and benefits) must be written in "lay language", (i.e.
understandable
to the people being asked to participate). The written presentation of
information is used to document the basis for consent and for the
subjects'
future reference.
-
The consent document should be revised when deficiencies are noted or
when
additional information will improve the consent process.
-
Use of the first person (e.g., "I understand that ...") can be
interpreted
as suggestive, may be relied upon as a substitute for sufficient
factual
information, and can constitute coercive influence over a subject. Use
of scientific jargon and legalese is not appropriate. Think of the
document
primarily as a teaching tool not as a legal instrument.
-
Describe the overall experience that will be encountered. Explain the
research
activity, how it is experimental (e.g., a new drug, extra tests,
separate
research records, or nonstandard means of management, such as flipping
a coin for random assignment or other design issues). Inform the human
subjects of the reasonably foreseeable harms, discomforts,
inconvenience
and risks that are associated with the research activity. If additional
risks are identified during the course of the research, the consent
process
and documentation will require revisions to inform subjects as they are
recontacted or newly contacted.
-
Describe the benefits that subjects may reasonably expect to encounter.
There may be none other than a sense of helping the public at large. If
payment is given to defray the incurred expense for participation, it
must
not be coercive in amount or method of distribution.
-
Describe any alternatives to participating in the research project. For
example, in drug studies the medication(s) may be available through
their
family doctor or clinic without the need to volunteer for the research
activity.
-
The regulations insist that the subjects be told the extent to which
their
personally identifiable private information will be held in confidence.
For example, some studies require disclosure of information to other
parties.
Some studies inherently are in need of a Certificate of Confidentiality
which protects the investigator from involuntary release
(e.g.,subpoena)
of the names or other identifying characteristics of research subjects.
The IRB will determine the level of adequate requirements for
confidentiality
in light of its mandate to ensure minimization of risk and
determination
that the residual risks warrant involvement of subjects.
-
If research-related injury (i.e. physical, psychological, social,
financial,
or otherwise) is possible in research that is more than minimal risk,
an
explanation must be given of whatever voluntary compensation and
treatment
will be provided. Note that the regulations do not limit injury to
"physical
injury". This is a common misinterpretation.
-
The regulations prohibit waiving or appearing to waive any legal rights
of subjects. Therefore, for example, consent language must be
carefully
selected that deals with what the institution is voluntarily willing to
do under circumstances, such as providing for compensation beyond the
provision
of immediate or therapeutic intervention in response to a
research-related
injury. In short, subjects should not be given the impression that they
have agreed to and are without recourse to seek satisfaction beyond the
institution's voluntarily chosen limits.
-
The regulations provide for the identification of contact persons who
would
be knowledgeable to answer questions of subjects about the research,
rights
as a research subject, and research-related injuries. These three areas
must be explicitly stated and addressed in the consent process and
documentation.
Furthermore, a single person is not likely to be appropriate to answer
questions in all areas. This is because of potential conflicts of
interest
or the appearance of such. Questions about the research are frequently
best answered by the investigator(s). However, questions about the
rights
of research subjects or research-related injuries (where applicable)
may
best be referred to those not on the research team. These questions
could
be addressed to the IRB, an ombudsman, an ethics committee, or other
informed
administrative body. Therefore, each consent document can be expected
to
have at least two names with local telephone numbers for contacts to
answer
questions in these specified areas.
-
The statement regarding voluntary participation and the right to
withdraw
are essential and can be taken almost verbatim from these regulations.
It is important not to overlook the need to point out that no penalty
or
loss of benefits will occur as a result of both not participating or
withdrawing
at any time. It is equally important to alert potential subjects to any
foreseeable consequences to them should they unilaterally withdraw
while
dependent on some intervention to maintain normal function.
-
The IRB may impose additional requirements that are not specifically
listed
in the regulations to ensure that adequate information is presented in
accordance with institutional policy and local law.
1. Determine
whether you need to file an IRB form
2. Find
The Necessary Forms
3. Examine
Helpful Tips To Ensure A Smooth Approval Process
4. Submission
Process
5. Begin
Research
6. Update
The IRB When You Have Completed Your Project
Updated 10/04