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SIOP Comments on Federal Policy for the Protection of Human Subjects


by SIOP Administrative Office

SIOP submitted comments December 21 to the Department of Health and Human Services in response to the Executive Branch’s proposed changes to the Federal Policy for the Protection of Human Subjects, otherwise known as the Common Rule. 

SIOP generally favored the proposed changes, as they would “provide greater flexibility and enhance efficiency of research activity review processes” in areas such as minimal risk studies and broad consent. 

The proposed changes that would likely benefit industrial and organizational (I-O) psychology include:

  • Introducing an “excluded” category (101(b)) for research activities, along with a list of activities that qualify for exclusion, which would be created and published by the Secretary of Health and Human Services.
  • Eliminating continuing reviews for minimal risk studies that qualify for expedited reviews (109(f)).
  • Allowing research subjects to give “broad consent” for secondary research use of information (104(f)(2)).
  • Allowing U.S. institutions engaged in a cooperative study to rely on a single IRB for the duration of the study (101(a)).

However, the Society cautioned that storing consent forms in a repository or allowing public access to the forms may reduce organizations’ participation in research. Organizations’ would likely want their employees’ organizational identifiers redacted.

“New pressures to address privacy, performance, and safety in the workplace have further expanded I-O psychology, emphasizing the importance of entire work systems, in addition to the individuals who contribute to them,” SIOP stated. “Recent events and conditions, including violence and incivility in the workplace, challenging economic circumstances, subtle and formal discrimination based on sexual orientation and gender, coping with talent shortages in technical jobs, and the implementation of new governmental regulations, catalyze the development and application of new methodologies for studying how people think and behave in the workplace.”

Read the full comments here.