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Jo Anna Risk, RN, MPH, CIP Education Coordinator Wayne State University IRB
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Adherence to DHHS regulations (Common Rule and FDA) Adherence to laws, regulations, and local customs in the country where research will take place Adherence to travel advisories and safety requirements Adherence to US Export Control policies and procedures
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Appropriate submission form Appropriate appendices, if needed (children, pregnant women, prisoners, the cognitively impaired) Consent/assent documents Surveys, interviews, advertisements Full research protocol Letters of support/local IRB review Export Control review
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Regulations-which country’s regulations do you follow? Political sensitivity to US regulations Knowing what regulations, laws, and guidelines for each country Cultural sensitivity-cultural context Language Informed Consent Rules for social-behavioral research Difference between official procedures and usual practices
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What are the norms, attitudes, beliefs of the people Specific attitudes toward certain medical conditions, treatments Social attitudes How the community would view the research Group consensus versus individual decisions Avoiding “Ugly American” syndrome
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Women’s rights to consent without spousal approval Language difficulties Who is in authority Individual vs community consent Community authority makes decision How seriously do official rules get followed (eg. Speed limits)
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No set rules or guidance documents for some countries Some countries would not understand the regulations under the Common Rule-privacy, confidentiality, personal autonomy, respect for individualism, rights of children to assent, rights of parents to consent for their children, Takes a bit of work to prepare for these Most of the development in regulations and guidance focuses on bio-medical research
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Local IRB Review If there is a local university that has an ethical review board, ask if they would be willing to review the research-key is to make sure research considers cultural norms and values If they do not have an IRB, for some studies, the PI must form one from the community-would need 5 members, with one non-scientist and a non-affiliated member. Local IRB may not be needed but WSU IRB makes this determination on case by case basis
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From local community leaders, government officials, state officials, organizations where the research takes place-must always check with local authorities Consider the community-may vary ◦ Chief of a tribe or community ◦ Local mayor ◦ Religious leaders ◦ Head of the family Should be written on official document or in other format, given the local context
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Must use translated documents-in language of group to be studied Forward and Backward translations-PI verification Certified Translations All consents, surveys, interview questions, etc. Persons obtaining consent should be fluent or have translator present Having an appropriate consent and translation can influence whether a study can go forward-gaining trust
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Will people who participate gain something over their fellow non-participants Must consider local goods and services when planning compensation Needs to be in line with local currency exchange in order not to be coercive Voluntariness may be an issue
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To Research Participants ◦ Would they be subject to backlash if community became aware of their participation? ◦ Would they be in danger? ◦ Have a plan to protect them. To Research Staff ◦ Careful planning prior to making the trip ◦ Utilize local leaders and community members ◦ Get the official or unofficial sanction of them first ◦ Have a plan for unexpected occurrences To the University ◦ Sound design, follow plan exactly, administrative review prior to conducting
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International research takes a longer period for the review.-allow 4-6 months ◦ Regular ethical and regulatory review by the local IRB ◦ Establishing relationship with country and required persons where research will take place ◦ Establishing an IRB, if needed ◦ Translations of documents ◦ Administrative review Export Control-Office of Research Compliance Administrative approval
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Each study may be different-Lorry Sabo, Office of Research Compliance-577-9064 ◦ eg5628@wayne.edu eg5628@wayne.edu Send her Title of study, Department, Letters of Support/IRB approvals in other country, English version of consent, IRB International Appendix A, Names of persons that will be contacts/ sponsors, organizations, groups to be included in study She will do a search to see if any person is on a Watch List Department of State –Embargos, sanctions,etc.
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OHRP Website on International Research: ◦ http://www.hhs.gov/ohrp/international/index.htmlhttp://www.hhs.gov/ohrp/international/index.html WSU OVPR Website on Export Control- ◦ http://www.research.wayne.edu/export- control/index.phphttp://www.research.wayne.edu/export- control/index.php WSU Policy on International Research: http://irb.wayne.edu/policies-human-research.php http://irb.wayne.edu/policies-human-research.php WSU IRB Education Coordinator: ◦ 313-577-9534
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