When deciding whether a project is oral history, the researcher’s intention plays a major role. HHS regulations [45 CFR 46.102(d)] define research as “a systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalizable knowledge.” As such, oral history activities that are intended to document an individual’s perspective on a particular historical event or way of life, without plans to draw conclusions or generalize findings, would not require IRB approval. In this scenario, the researcher intends to let the individual’s stories stand-alone, without further interpretation or analysis.
If, however, a researcher plans to survey or interview participants with the intent of comparing, contrasting, and/or establishing commonalities between different individuals or groups of individuals, this would be subject to IRB review and approval. Oral historians focus on and communicate a particular, certain past; they do not attempt to explain why something has happened, and they do not attempt to predict the future.
Individuals participating in an oral history interview or survey are not anonymous or randomly selected. They are chosen based on their close relationship to the topic or event. Oral history provides a unique perspective (or group of perspectives) about the topic or event. It does not provide information or results that can be generalized to all individuals associated with that topic or event. Content analyses, discourse analyses, thematic coding, or other types of qualitative data analyses are not performed on oral history results.
Oral historians may also not create archives with the intent of providing a repository of information for others to conduct research. The creation of such an archive would constitute “research” under the HHS regulations 45 CFR part 46, and would therefore be subject to IRB review and approval.
Here are some examples of qualitative interviews that may or may not be considered oral history:
- An oral history video recording of interviews with Holocaust survivors is created for viewing in the Holocaust Museum. The creation of the video tape does NOT intend to draw conclusions, inform policy, or generalize findings. The sole purpose is to create a historical record of specific, personal events and experiences related to the Holocaust and provide a venue for Holocaust survivors to tell their stories.
- This scenario would be considered oral history activities that ONLY document a specific historical event or the experiences of individuals, without the intent to draw conclusions or generalize findings. It WOULD NOT constitute “research” as defined by HHS regulations 45 CFR part 46.
- An open ended interview of surviving Gulf War veterans to document their experiences and draw conclusions about their experiences, inform policy, or generalize findings.
- This scenario would be considered a systematic investigation that is designed to develop or contribute to generalizable knowledge. It WOULD constitute “research” as defined by HHS regulations 45 CFR part 46.
- Open ended interviews are conducted with surviving Negro League Baseball players, in order to create an archive for future research.
- This scenario would be considered open-ended interviews conducted with the intent to create an archive for the purposes of providing a resource for others to conduct research. Proper consent would be needed and the scenario WOULD then constitute “research” as defined by HHS regulations 45 CFR part 46.
In all scenarios, we suggest that the researcher contact our office directly to make an official determination. To aid in this determination, the “Determination of Human Subjects Research Worksheet” can be submitted via the iRIS system (please see the"How to Submit a Determination of Human Research Worksheet" page for instructions on submitting). This form will be reviewed by an IRB Chair or Vice Chair, and an official determination will be emailed to you in an IRB outcome letter.
Just a note, although additional guidance has been proposed by the HHS, this new language has not been finalized and can therefore not be instituted at this time. Once finalized, the OU IRB will revisit the current guidance and polices and makes changes accordingly.
Please contact our office if you have any questions/comments/concerns regarding this guidance. Our phone number is 405-325-8110 and our email address is email@example.com. Thank you.
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