In 2002, the Oral History Association and the American Historical Association announced that the Office of Human Research Protections (OHRP) had concurred most oral history projects are not research as defined by the HHS regulations governing human subjects research. In December 2003, Michael Carome, OHRP’s Associate Director for Regulatory Affairs, issued the following additional guidance: OHRP Oral History Guidance.
In short, Carome’s guidance maintains that so long as oral history activities meet the federal definition of research according to 45 CFR 46.102(d), then they are still subject to IRB review. Most oral history activities are either a) systematic investigations designed to draw conclusions/generalize findings or b) designed to produce materials for permanent archiving in the library. Carome’s guidance cites these two types of oral history activities as ones that continue to require IRB review and approval.
Accordingly, no revisions will be made at this time to our institutional policies, and the IRB will continue to assess the need for review of oral history projects on a case by case basis.