Oral History and Institutional Review Board (IRB)
The California State University, Dominguez Hills IRB will continue to review all theses that involve oral history methodology. All other oral history projects will be reviewed if they meet the following criteria:
- there is an intention to create generalizable principles of historical or social development
- there is an intention to identify underlying principles or laws of nature that have predictive value and can be applied to other circumstances for the purpose of controlling outcomes.
Application of the Department of Health and Human Services Regulations for the Protection of Human Subjects at 45 CFR Part 46, Subpart A to Oral History Interviewing
Most oral history interviewing projects are not subject to the requirements of the Department of Health and Human Services (HHS) regulations for the protection of human subjects at 45 CFR part 46, subpart A, and can be excluded from institutional review board (IRB) oversight because they do not involve research as defined by the HHS regulations. HHS regulations at 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." The Oral History Association defines oral history as "a method of gathering and preserving historical information through recorded interviews with participants in past events and ways of life."
It is primarily on the grounds that oral history interviews, in general, are not designed to contribute to "generalizable knowledge" that they are not subject to the requirements of the HHS regulations at 45 CFR part 46 and, therefore, can be excluded from IRB review. Although the HHS regulations do not define "generalizable knowledge," it is reasonable to assume that they term does not simply mean knowledge that lends itself to generalizations, which characterizes every form of scholarly inquiry and human communication. While historians reach for meaning that goes beyond the specific subject of their inquiry, unlike researchers in the biomedical and behavioral sciences they do not reach for generalizable principles of historical or social development, nor do they seek underlying principles or laws of nature that have predictive value and can be applied to other circumstances for the purpose of controlling outcomes. Historians explain a particular past; they do not create general explanations about all that has happened in the past, nor do they predict the future.
Moreover, oral history narrators are not anonymous individuals, selected as part of a random sample for the purposes of a survey. Nor are they asked to respond to a standard questionnaire administered to a broad swath of the population. Those interviewed are specific individuals selected because of their often unique relationship to the topic at hand. Open-ended questions are tailored to the experiences of the individual narrator. Although interviews are guided by professional protocols, the way any individual interview unfolds simply cannot be predicted. An interview gives a unique perspective on the topic at hand; a series of interviews offer up not similar "generalizable" information but a variety of particular perspectives on the topic.
For these reasons, then, oral history interviewing, in general, does not meet the regulatory definition of research as articulated in 45 CFR part 46. The Office for Human Research Protections concurs with this policy statement, and it is essential that such an interpretation be made available to the many IRBs currently grappling with issues of human subject research.