Expedited Review

The Secretary, DHHS, has established, and published as a Notice in the Federal Register, a list of categories of research that may be reviewed by the IRB through an expedited review procedure.

The categories in this list apply regardless of the age of subjects, except as noted.

The IRB chair, vice chair or member designee in accordance with the requirements set forth in 45 CFR 46.110 will review the protocol submission and determine if the research meets the criteria for expedited review.

In reviewing the research, the reviewers may exercise all of the authorities of the IRB, except that the reviewers may not disapprove the research. When a reviewer cannot approve the research under expedited review, the study is remanded to the full IRB for review at its next scheduled meeting.

The UVA IRBs will keep members advised of protocols approved by expedited means by providing written document of all expedited approvals at full board meetings and note this in the meeting minutes

Types of research that may not be approved by expedited review:

  • Projects involving classified research cannot be completed by expedited review.
  • Projects involving identification of the subjects and/or their responses which would reasonably place them at risk of criminal or civil liability or be damaging to the subjects' financial standing, employability, insurability, reputation, or be stigmatizing, unless reasonable and appropriate protections will be implemented so that risks related to invasion of privacy and breach of confidentiality are no greater than minimal.

Examples:

Additional examples of types of studies that may be allowed under an expedited review process may be found in the Risk Assessment Tool- Expedited vs Full Board Review.

Categories of research that may be reviewed by the IRB through an expedited review:

Research activities that 

  1. present no more than minimal risk to human subjects, and
  2. involve only procedures listed in one or more of the following categories may be reviewed by the IRB through the expedited review procedures authorized by 45 CFR 46.110 and 21 CFR 56.110.

The activities listed should not be deemed to be of minimal risk simply because they are included on this list.

Inclusion of this list merely means that the activity is eligible for review through the expedited review procedures when specific circumstances of the proposed research involve no more than minimal risk to human subjects.

Though the Federal regulations state that the categories in this list apply regardless of the age of the subject, the vulnerable population stipulations still apply.

Investigators are reminded that the standard requirements for informed consent apply regardless of the type of review utilized by the IRB. Expedited review procedures do not release the investigator from the obligation of obtaining informed consent or authorization from human subjects enrolled in the research.

The categories eligible for expedited review in accordance with 45 CFR 46.110 and 21 CFR 56.110 are:

1. Clinical studies of drugs and medical devices only when conditions (a) or (b) is met:

(a) Research on drugs for which an investigational new drug application is not required. (Note: Research on marketed drugs that significantly increases the risks associated with the use of the drug is not eligible for expedited review.)

(b) Research on medical devices for which (i) an investigational device exemption (IDE) application 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:

(a) 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 two times per week; or

(b) From other adults and children considering the age, weight, and health of the subjects, the collection procedure, the amount of blood 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 two times per week.

3. Prospective collection of biological specimens for research purposes by noninvasive means. Examples:

(a) hair and nail clippings in a non-disfiguring manner;

(b) deciduous teeth at the time of exfoliation or if routine subject care indicates a need for extraction;

(c) permanent teeth if routine subject care indicates a need for extraction;

(d) excreta and external secretions (including sweat);

(e) uncannulated salvia collected either in an unstimulated fashion or stimulated by chewing gum base or wax or by applying a diluted citric solution to the tongue;

(f) placenta removed at delivery;

(g) amniotic fluid obtained at the time of rupture of the membrane prior to or during delivery;

(h)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;

(i) mucosal and skin cells collected by buccal swab, skin swab, or mouth washings;

(j) sputum collected after saline mist nebulization.

4. Collection of data through non-invasive procedures (not involving general anesthesia or sedation) 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.) Examples of non-invasive procedures that may qualify for expedited review are

(a) physical sensors that are applied either to the surface of the body or at a distance and do not involve the input of significant amounts of energy into the subject or an invasion of the subject's privacy;

(b) weighing or testing sensory acuity;

(c) magnetic resonance imaging

(d) electrocardiograph, ultrasound, electroencephalography, thermography, detection of naturally occurring radioactivity, electroretinography, diagnostic infrared imaging, doppler blood flow, and echo-cardiography;

(e) 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 solely for non-research purposes (such as medical treatment and/or diagnosis). (Note: Some research in this category may be exempt from IRB regulations for the protection of human subjects (45 CFR 46.101(b)(4). This listing refers only to research that is not exempt.

6. Collection of data from voice, video, digital or image recordings 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 IRB 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 IRB as follows:

(a) 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

(b) where no subjects have been enrolled and no additional risks have been identified; or

(c) 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) through (8) do not apply but the IRB has determined and documented at a convened full IRB meeting that the research involves no greater than minimal risk and no additional risks have been identified.

Deadline to Incorporate Pre-Review Recommendations

When a protocol is pre-reviewed, the investigator will receive correspondence detailing requests for revisions, clarification, or additional information. When the modifications are made and submitted to the IRB, they are reviewed by administrative staff.

The investigator has 90 days to respond to the revisions requested.  If the investigator does not respond in 90 days, the application is withdrawn and returned to the investigator. If the investigator wishes to conduct a study that has been withdrawn, the investigator must submit  a new application, incorporating comments from the prior IRB review.