Michael Pritchard's Commentary on "Ethical Issues in Student Research"

Like most institutions of higher learning, James Bower’s university holds that research done only for educational purposes does not come directly under the purview of the IRB.  However, many such institutions require instructors to submit a statement to the IRB indicating the sorts of research that students will be undertaking.  Although individual protocols are not submitted, this enables the IRB to provide cautionary advice about potentially problematic kinds of research that students might wish to undertake.

As this case illustrates, it is possible that particular research projects undertaken only for educational purposes can nevertheless raise unanticipated, serious problems.  IRBs are designed to protect the rights and welfare of human participants.  However, the protection to which participants are entitled is not confined only to those areas that come directly under the purview of an IRB.  What justification, then, can be given for not requiring research done only for educational purposes to be reviewed by an IRB?  First, administratively, requiring every student to submit a protocol would be very time consuming and require a substantial increase in IRB staffing.  Second, given the relative shortness of the standard semester, it might make it much more difficult for students to complete their research projects.  Third, there may be an assumption that instructors will adequately supervise the research projects undertaken by students and not permit them to place participants at more than minimal risk of harm.  So, we might be tempted to say, some sort of procedural compromise is reasonable.

Nevertheless, this should not come at the expense of protecting human participants in research, whether or not this is undertaken for educational purposes only.  Especially since the researchers are inexperienced undergraduates who are just “learning the ropes” in research, careful monitoring of this research is important. 

In this case, the instructor is a graduate student, who himself seems to be relatively inexperienced. It is disturbing that, although James is teaching under the supervision of Dr. Holden, there is no evidence that this aspect of his teaching has received any supervision.  In fact, it does not seem to have occurred to James that he could consult with Dr. Holden about what sorts of research projects by his students would be acceptable.  Why would James talk only with his fellow graduate students?  Something seems seriously amiss here, and perhaps in the department generally, as other graduate students seem to have proceeded unsupervised as well.

The fact that James does not anticipate the risks posed by his students’s depression survey indicates either his lack of experience or indifference on his part.  What would Dr. Holden have advised?  Had he been consulted, he might well have told James that he should not allow this sort of survey to be conducted, at least not without IRB review.  A worry is that Dr. Holden might actually share the attitude of James’s fellow graduate students — if the research falls outside the purview of the IRB, don’t worry about it.

Meanwhile, the survey is conducted by the undergraduate students, presumably unaware that further responsibilities may fall on their shoulders (and James’s) once they learn the results.  How to proceed once they learn that there may be two students who could use professional help with their depression is a difficult issue.  In an effort to preserve anonymity, James reports to the entire class that several students may be suffering from depression.  “Which ones?” the students might ask.  “We cannot tell you directly,” James would reply.  “But if you reported more than four symptoms of depression, you should contact the university behavioral health center.”  How are the students to determine how many symptoms of depression they reported?  Was the survey so direct?  Did it label the symptoms for the students?  Is it likely that only two students will think that they have identified four or more symptoms?  And will it be the right two students?

Unfortunately, James probably has no experience dealing with situations like this, or even with thinking about them.  One of the functions of an IRB is to help researchers anticipate such problems and settle on a good procedure for dealing with them should they arise.  James has deprived himself of all access to this sort of help by failing to communicate with either his supervisor, Dr. Holden, or the IRB.

However, the fact is that the survey placed undergraduate students at risk of harm.  Consider this as a guiding principle: Even if you are not seeking to contribute to generalizable knowledge in your research, you still need to worry about whether your research places anyone at risk.  Saying that risks to participants matter only when generalizable knowledge is sought makes no moral sense.  So, risks matter even if they do not fall under the direct purview of an IRB.  This seems to imply that Dr. Holden has a responsible role to play in this, but chose not to accept it, negligently ignored it, or was somehow denied the opportunity to assume it. 

At the very least, James should have been informed at the outset by Dr. Holden that he should be given the opportunity to review the sorts of research projects proposed by students.  However, a conscientious IRB would also do its best to make all teachers, professors and graduate students alike, aware of its willingness (and desire) to address questions regarding the protection of human participants in any research involving the institution it is serving.