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Institutional Review Board (IRB) FAQ

by Data Services, revised June 11, 2010

Note: The following IRB questions and answers apply specifically to PSC faculty, post-docs and students.

How do I apply for IRB approval?

Go to the eResearch on-line application system. There is a FAQ area but if you run into any problems, come see us for help. You can also modify an existing application (e.g., add another data file to it).

What is PEERRS?

PEERRS (Program for Education and Evaluation in Responsible Research and Scholarship) is an on-line instructional and certification program for the research community. PEERRS training replaces the Human Subjects Training previously offered by UM and fulfills the NIH requirement for human subjects training for PIs and "key personnel."

The Human Subjects module is required. Other modules are Foundations of Responsible Research Conduct, Research Administration, and Conflict of Interest, Authorship, Publication and Peer Review and Animal Subjects.  The required training you need is based on your IRB board’s requirements, which is provided here.

Another way to determine what training you need is based on the answers you provided to a short survey the first time you logged into PEERRS.  A curriculum is assigned to you based on your profile.  You can make changes to your profile if your role changes, e.g., your research role changes, or the department you are associated with changes, etc.  This might change the certifications that you need.

You must have PEERS certification before you can initiate an IRB application.  The certification must be up-to-date.  Typically, certification in a subject area lasts 3 years.

I am using secondary data in my research.  Doesn’t secondary data qualify for an exemption from human subjects regulations?

IRB approval is not needed for secondary data that are public use files.  The Michigan IRB defines public use data as data disseminated by ICPSR and Roper and the following federal agencies (Census Bureau, NCHS, and NCES).   

IRB approval is needed for public data that falls outside this definition, such as files at Sociometrics.  Specific data files can be added to the pre-approved list by applying for an exemption.  For instance, data from the National Election Studies and the Health and Retirement Study do not require prior IRB approval.

The most common reason for IRB review of secondary data is for restricted data, e.g., geocoded data from NLS or PSID, or the HRS social security files.  Please see us for examples of successful IRB applications of these types of data. 

Other issues such as tabular data and merging are covered in this summary of the UM policy.

I already have approval to use a dating website for a project on assortative mating. Do I need approval for using these same data to examine the relationship between education and religious identity?

Yes. The IRB approval is for research, not data.

Does unfunded research have to have IRB approval?

Yes. All research using non-public data has to have IRB approval - not just funded projects.

Does student research require IRB approval?

Yes, but students, post-docs, and research staff working on a larger project are covered by the project leader's IRB approval. Check with your mentor.

If a student or post-doc is doing independent work that does not fall under the mentor's project (funded or not), the student/post-doc researcher needs to apply/get approval for the research project.

Do I need IRB approval for every file I look at?

No. Exploratory work does not need IRB approval. However, once you are running models, talking with others about what you are doing, presenting a brown bag, etc. you need IRB approval.   In fact, most restricted data applications require IRB approval before release of the restricted data to you.  Likewise, university officials will not sign off on a restricted data request without IRB approval.

You cannot get retrospective IRB approval. If something gets published and it does not have IRB approval you could be in trouble.

I'm teaching a class where the students will be using data. What am I supposed to do?

A statistics class or a quantitative reasoning class that uses data as part of the teaching process will be exempt because the class is not doing research. However, the instructor should not assume that all classroom use of data are exempt. Read the following, which provides clarification for when a class assignment requires IRB approval.