Statement on Oral History and Institutional Review Boards

At its meeting on June 5, 2004, the Council of the American Historical Association unanimously adopted the following statement:

The Council of the American Historical Association is pleased that many colleges and universities have excluded most forms of oral history from regulations governing human subjects research, since the federal Office for Human Research Protection concurred with the joint AHA/OHA Policy Statement (reprinted below). We note with regret, however, the reluctance of some Institutional Review Boards (IRBs) to accept these recommendations.

We reaffirm our support of the policy statement's assertion that "oral history interviewing activities, in general, are not designed to contribute to generalizable knowledge and, therefore, do not involve research as defined by Department of Health and Human Services regulations at 45 CFR 46.102(d) and do not need to be reviewed by an institutional review board."

We urge the adoption of this policy by all IRBs, to ensure a consistent nationwide policy, which will enable historians to pursue this important avenue of research without unnecessary constraints.

OHA/AHA Policy Statement

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.

[See letter of concurrence from Michael A. Carome, Associate Director, Office for Human Research Protections]