FAQs Human Subjects Research International Settings RICRO: (970) 491-1553 [email protected] 601 S. Howes, Suite #208 University Services Center Where do I find International Research in the Code of Federal Regulations? Please see §46.101.h: http://www.hhs.gov/ohrp/humansubjects/guidance/45cfr46.html (h) When research covered by this policy takes place in foreign countries, procedures normally followed in the foreign countries to protect human subjects may differ from those set forth in this policy. [An example is a foreign institution which complies with guidelines consistent with the World Medical Assembly Declaration (Declaration of Helsinki amended 1989) issued either by sovereign states or by an organization whose function for the protection of human research subjects is internationally recognized.] In these circumstances, if a department or agency head determines that the procedures prescribed by the institution afford protections that are at least equivalent to those provided in this policy, the department or agency head may approve the substitution of the foreign procedures in lieu of the procedural requirements provided in this policy. Except when otherwise required by statute, Executive Order, or the department or agency head, notices of these actions as they occur will be published in the FEDERAL REGISTER or will be otherwise published as provided in department or agency procedures. How far in advance of leaving the country should I plan to submit my protocol? Whether you are a CSU faculty member, staff or student, your human subjects’ research study must be approved by the IRB before it can be implemented. We suggest you apply to the IRB at least two months before you leave the United States to ensure adequate time for review and approval before you leave the country. Bring your written IRB approval notification with you on your trip. In addition to IRB Ethics Board review and approval, am I required to contact the consulate or ministry in country to register my research with the government abroad? You may be. Please refer to the 2015 Edition of the International Compilation of Human Research Protections from the Office of Human Research Protections. This document provides links and information regarding regulations for research in many countries: http://ricro.colostate.edu/IRB/documents/2015internationalcompilation.pdf I have a grant that is funded by NIH, and I will be collaborating with a researcher at another academic institution abroad. Are both institutions required to review the protocol? For research that is sponsored by a U.S. Federal agency, where CSU is the prime grantee of the award, the CSU investigator is responsible for ensuring that all engaged international sites hold a federalwide assurance, and that the research is approved by the IRB or Ethics Committee of the participating sites listed on the federalwide assurance. In some circumstances, the IRB may approve an IAA (IRB Authorization Agreement) between the two institutions, but this will depend on the activities that each Investigator will perform. You can find International FWA information for specific International institutions here (select Advanced Search to find International institutions): http://ohrp.cit.nih.gov/search/fwasearch.aspx?styp=bsc. Contact the IRB Coordinators for IAA applicability: [email protected] 4/13/2015 I am working with an international NGO, and they have agreed to assist me with my research by providing access to the community. What sort of documentation do I need to provide the IRB to document this NGO’s agreement to assist me with my research? If the organization’s role is limited to assisting you with recruitment/access to potential participants, the CSU IRB require that you obtain a letter or email from the organization to document their agreement to assist you and to outline their role in your research. If you do not have this document at the submission of your protocol, please inform the IRB that this is in process. Your protocol can be reviewed and approved with receipt of this documentation as a condition of approval. Please see “Letters of Cooperation” here: http://ricro.colostate.edu/IRB/MiscellaneousTemplates.html A staff member at an international NGO will be considered a Co-Investigator on my research (e.g., will consent participants, collect data, and co-author manuscripts). How can I establish this relationship? Can I add this person to my eProtocol? Is this collaborator required to have human subjects’ protection training? If foreign staff will be engaged with your research and the organization does not have its own FWA, the CSU IRB may agree to extend our FWA to cover this individual investigator. The NGO staff member would need to have documented Human Subjects Protection training, and we would enter into an IIA (Individual Investigator Agreement) with this investigator. Please inform the IRB at submission that individuals at the NGO will be engaged in your research so the agreement process can be discussed by the IRB and initiated as soon as possible. For more information regarding IIAs, see: http://www.hhs.gov/ohrp/policy/guidanceonalternativetofwa.html. The NGO staff member can be added to eProtocol under the “Other Researcher or Key Personnel” role. Note that they will not have viewing or editing access to the protocol. Should I submit translated research instruments, recruitment, and consent with my initial protocol submission or should I wait until the protocol forms have all been approved in English first? The translated finalized research instruments, recruitment and consent are required to be submitted to the IRB to complete your eFile. Since the IRB may request that you make changes to your consent or recruitment, please wait until these documents have been approved by the IRB before submitting your translated documents. The translated files can be submitted to the IRB as a postapproval amendment via eProtocol. I would like to provide some compensation to my participants. What does the IRB consider to be coercive when providing participants incentives internationally? As with any compensation or incentives, payments should reflect the degree of risk, inconvenience, or discomfort associated with participation. Compensation should not be so large as to persuade participants to consent to the research against their better judgment. Compensation is provided to participants for their time spent and inconvenience. Items such as rice, tea, t-shirts, or mugs are also considered compensation. Careful consideration should be made to the economic status of the region. While providing $10 may not seem coercive to you, this amount may be the average weekly salary for individuals in the region, thus creating undue influence. When recruiting and consenting participants internationally, is it always required that I ask my participants to sign a consent form? What are my consent options? The key consideration is the cultural context. What matters is that the participant can be fully informed and understand what your research is about, and what you are asking them to do, NOT a particular form. The IRB is receptive to proposals for “non-traditional” means to convey consent. In principle, YOU and your local collaborators should know best HOW to meet the spirit of informed consent. Obtaining signed consent from human subjects may not be culturally acceptable in the country where you will be conducting your research. Using an oral script, short 4/13/2015 cover letter, picture boards, videos, or a mobile app may be appropriate for your population. For templates for oral consent and a study summary that you can customize and provide your participants, please see our templates here: http://ricro.colostate.edu/IRB/ConsentAssentTemplates.html Should the CSU IRB contact information be given to participants, or should I provide participants a local contact to serve as the subjects’ rights contact? It is the IRB’s strong preference that you provide a local subjects’ rights contact as the RICRO coordinators are not able to assist in multiple languages, and it is best not to ask your participants to place international phone calls. Are there any issues I should be aware of regarding taking my computer with me internationally? Please check with the Export Control Administrator regarding taking your computer with you internationally. What are the major considerations that the IRB reviewers are focusing on when reviewing international research protocols? CSU Researchers and the CSU IRB share the responsibilities to ensure that human participants are provided the same or equivalent protections as provided participants in any research location. In order to review the risk-to-benefits ratio, the reviewers would like to see that you have knowledge of the local laws and the cultural context, the consent process is appropriate, required local and/or International approvals are in place, and that you have developed a data management plan. As you prepare your international research protocol, please refer to the International Research Checklist available here: http://ricro.colostate.edu/IRB/Researchers.html Institutional Review Board (IRB) Contacts: Evelyn Swiss, Senior IRB Coordinator and Tammy Felton-Noyle, Assistant IRB Coordinator [email protected] 970-491-1553 Matt Hickey, Ph.D., Professor, Health & Exercise Science, IRB Chair [email protected] 970-491-5727 International Education/Office of International Programs Laura Thornes, Director, Study Aboard [email protected] 970-491-2964 Export Control Scot Allen, Export Control Administrator [email protected] 970-491-1563 4/13/2015 Additional references: Office of Human Research Protections International OHRP- Terms of the Federalwide Assurance 2015 Edition International Compilation of Human Research Standards OHRP – Sample Short Form NIH Bioethics Resources on the Web World Medical Association – Helsinki- Ethical Principles for Research Involving Human Subjects European Union General Data Protection Regulation International Ethical Guidelines for Biomedical Research Involving Human Subjects (CIOMS) International Conference on Harmonisation (ICH) Guidance Documents Harvard School of Public Health – Global Research Ethics Map 4/13/2015 http://www.hhs.gov/ohrp/international/ http://www.hhs.gov/ohrp/assurances/forms/fwatermsjun14.pdf http://ricro.colostate.edu/IRB/documents/2015internationalcompilation.pdf http://www.hhs.gov/ohrp/policy/ic-non-e.html#sample http://bioethics.od.nih.gov/index.html http://www.wma.net/en/30publications/10policies/b3/index.html http://ec.europa.eu/justice/dataprotection/document/review2012/com_2012_11_en.pdf http://www.cioms.ch/publications/layout_guide2002.pdf http://www.fda.gov/RegulatoryInformation/Guidances/ucm122049.htm https://webapps.sph.harvard.edu/live/gremap/index_main.cfm?CFID=1356404 7&CFTOKEN=31710985
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