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The Office of Human Research Protection (OHRP) supports the idea of IRBs from collaborating institutions also collaborating – in essence, permitting one institution’s IRB to defer review of a human subjects research application to another IRB. This collaboration eliminates redundancies in the review of a study, and may provide a more efficient process. In order for the JHSPH IRB to consider such an arrangement, the following must be true:
- Both IRBs must have a Federal-Wide Assurance from the OHRP
- The role of the investigator associated with the deferring IRB’s institution may not involve interaction with a human subject; the role should be limited to that of study development, design or advice, and/or analyzing data
The reason for this limitation is that investigators who are involved in the human subjects intervention or interaction bear a greater responsibility for the safety of those subjects, and their institution bears the liability for those activities. Thus, in our view, that institution’s IRB should not cede review responsibility to the collaborating institution’s IRB, unless extenuating circumstances exist.