In September, 2003, the Office of Human Research Protections (DHHS) issued a letter to the Pennsylvania Historical and Museum Commission concerning the need for review of oral history being collected by the Commission. This letter has led some New York University investigators, among many others, who make use of oral history in research to ask for clarification of OHRP's position as it affects the need for investigators to apply to the University Committee on Activities Involving Human Subjects (UCAIHS), NYU's Institutional Review Board (IRB), for review and approval of such work.
In response to an inquiry on this topic from Northeastern Illinois University, Dr. Michael Carome of the DHHS Office of Human Research Protections issued, on Dec. 1, 2003, a clarification of the Pennsylvania decision as it might apply to other situations. This clarification makes it clear that investigators are likely to continue to need UCAIHS approval for projects involving human subjects. The following excerpt from Dr. Carome's response to NIU details the circumstances under which oral history does or does not need IRB review and approval:
Until the regulations governing the use of human subjects in research are revised or OHRP changes the policies cited above, investigators at the University should continue to apply to the UCAIHS for review and approval of all activities involving human subjects. Dissertations or theses that include human subjects are by definition considered to be research and are therefore required to be reviewed by the UCAIHS. Investigators requiring advice on how to categorize a particular project involving oral history should contact the UCAIHS staff.