Expedited Category Review | What is Expedited Review | What are the Criteria | What is the definition of minimal risk | Who decides whether or not a project has “minimal risk” | What Research Categories fall under Expedited Category Review | What is the application process | How will I know that a Protocol has been approved | Who receives these IRB Action Notices | What happens if my Expedited Review does not qualify
These research categories 1-9 apply regardless of the age of subjects, except as noted. Researchers are reminded that the standard requirements for informed consent (or its waiver, alteration, or exception) also apply to Expedited Review.
Also note that some of these categories have very specific requirements and elements. Contact OReC if you have any questions about whether or not your project may be reviewed under “expedited” procedures.
(1) Clinical studies of drugs and medical devices only when condition (1) or (2) is met.
1. Research on drugs for which an investigational new drug application (21 CFR Part 312) is not required. (Note: Research on marketed drugs that significantly increases the risks or decreases the acceptability of the risks associated with the use of the product is NOT eligible for expedited review.)
2. Research on medical devices for which (i) an investigational device exemption application (21 CFR Part 812) is not required; or (ii) the medical device is cleared/approved for marketing and the medical device is being used in accordance with its cleared/approved labeling.
(2) Collection of blood samples by finger stick, heel stick, ear stick, or venipuncture as follows:
- from healthy, non-pregnant adults who weigh at least 110 pounds. For these subjects, the amounts drawn may not exceed 550 ml in an 8 week period and collection may not occur more frequently than 2 times per week; or
- from other adults and children, considering the age, weight, and health of the subjects, the collection procedure, the amount of blood to be collected, and the frequency with which it will be collected. For these subjects, the amount drawn may not exceed the lesser of 50 ml or 3 ml per kg in an 8 week period and collection may not occur more frequently than 2 times per week.
As a reminder, 1 ml is equal to 1 cc. In addition, 1 cc is approximately 1/5 of a teaspoon. When reporting the total amount of blood drawn from a subject, it may be easier for potential subjects to understand “teaspoons” rather than ml or cc (using teaspoons is a more user-friendly term for participants). Here is another helpful conversion chart investigators may use when describing blood draw amounts in consent documents:
|10 cc or ml = 2 teaspoons|
|15 cc or ml = 1 tablespoon|
(3) Prospective collection of biological specimens for research purposes by noninvasive means.
- hair and nail clippings in a non-disfiguring manner;
- deciduous teeth at time of exfoliation or if routine patient care indicates a need for extraction;
- permanent teeth if routine patient care indicates a need for extraction;
- excreta and external secretions (including sweat);
- uncannulated saliva collected either in an unstimulated fashion or stimulated by chewing gumbase or wax or by applying a dilute citric solution to the tongue;
- placenta removed at delivery;
- amniotic fluid obtained at the time of rupture of the membrane prior to or during labor;
- supra- and subgingival dental plaque and calculus, provided the collection procedure is not more invasive than routine prophylactic scaling of the teeth and the process is accomplished in accordance with accepted prophylactic techniques;
- mucosal and skin cells collected by buccal scraping or swab, skin swab, or mouth washings; sputum collected after saline mist nebulization.
*Note that collection of biospecimens may also require permission from agencies, offices and institutions (safety office, biohazard officials, hospitals, clinics, etc.) as well as from patients/research subjects. Also note that other “non-IRB” rules and regulations may be involved with the collection of biospecimens.
(4) Collection of data through noninvasive procedures (not involving general anesthesia or sedation) routinely employed in clinical practice, excluding procedures involving x-rays or microwaves.
Where medical devices are employed, they must be cleared/approved for marketing. (Studies intended to evaluate the safety and effectiveness of the medical device are NOT generally eligible for expedited review, including studies of cleared medical devices for new indications.)
- physical sensors that are applied either to the surface of the body or at a distance and do not involve input of significant amounts of energy into the subject or an invasion of the subject’s privacy;
- weighing or testing sensory acuity;
- magnetic resonance imaging;
- electrocardiography, electroencephalography, thermography, detection of naturally occurring radioactivity, electroretinography, ultrasound, diagnostic infrared imaging, Doppler blood flow, and echocardiography;
- moderate exercise, muscular strength testing, body composition assessment, and flexibility testing where appropriate given the age, weight, and health of the individual.
(5) Research involving materials (data, documents, records, or specimens) that have been collected, or will be collected solely for nonresearch purposes (such as medical treatment or diagnosis).
Examples of this type of research might involve:
- medical chart reviews
- analyses performed on existing databases where the information was originally generated for non-research purposes (such as clinical registries, clinical datasets, etc.)
- analyses performed on “discarded” specimens (blood, bone, tissue, proteins, genetic materials, etc.) which were collected as a part of a subject’s routine medical visit (not associated with any aspect of research)
(6)Collection of data from voice, video, digital, or image recordings made for research purposes.
(7) Research on individual or group characteristics or behavior (including, but not limited to, research on perception, cognition, motivation, identity, language, communication, cultural beliefs or practices, and social behavior) or research employing survey, interview, oral history, focus group, program evaluation, human factors evaluation, or quality assurance methodologies.
(NOTE: Some research in this category may be exempt from the HHS regulations for the protection of human subjects. 45 CFR 46.101(b)(2) and (b)(3). This listing refers only to research that is not exempt.)
(8) Continuing review of research previously approved by the convened IRB as follows:
- where (i) the research is permanently closed to the enrollment of new subjects; (ii) all subjects have completed all research-related interventions; and (iii) the research remains active only for long-term follow-up of subjects; or
- where no subjects have been enrolled and no additional risks have been identified; or
- where the remaining research activities are limited to data analysis.
(9) Continuing review of research, not conducted under an investigational new drug application or investigational device exemption where categories 2-8 do not apply but the IRB has determined and documented at a convened meeting that the research involves no greater than minimal risk and no additional risks have been identified.
Note that the different activities listed under each of these categories of research, does not automatically deem these projects as minimal risk simply because they are presented here. Providing an exhaustive list of all of the possible research activities eligible for expedited review would be, well, “exhausting.” The activities presented here only indicate that a significant portion of these types of research activities could be eligible for review through expedited review procedures. In addition, this eligibility also depends on whether or not the specific circumstances surrounding the proposed research activities involves no more than minimal risk to the participating subjects. Decisions regarding eligibility for expedited review will be made on a case-by-case basis, by the OReC and the IRB chair.