Institutional Review Board
Institutional Review Board: Structure, Function, and Protocol Review · Also known as: IRB, Research Ethics Committee, REC
The Institutional Review Board (IRB) is the independent ethics committee established at research institutions to review and approve human subjects research, ensuring compliance with ethical principles and federal regulations. Created as a legal requirement by the U.S. National Research Act (1974) and now adopted globally, the IRB serves as the primary mechanism for protecting research subjects while enabling legitimate research to proceed. No human subjects research can begin without IRB approval.
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When to use it
IRB review is mandatory for: (1) Any research involving human subjects that is federally funded (explicitly required by law). (2) Any research at an institution that holds a Federalwide Assurance (FWA) agreement with HHS—most academic and medical institutions hold FWA, committing to IRB review of all human subjects research regardless of funding. (3) Research involving interventions (drugs, procedures, surveys, behavioral manipulations). (4) Research collecting identifiable private information (health data, survey responses). (5) Research using biological specimens from identifiable persons. Exempt from IRB review (under 45 CFR 46.104): (a) Research using existing data/documents that are de-identified; (b) Research involving only publicly available information without identifiers; (c) Some educational research and quality improvement initiatives. Contact your IRB to determine if your research requires review—most institutions have web portals and staff to assist.
Strengths & limitations
- Provides independent, objective ethics review: IRB members are not invested in research success, reducing researcher bias about acceptable risks.
- Multidisciplinary perspective: IRB composition (scientist, clinician, ethicist, community member) ensures research evaluated from multiple viewpoints, catching ethical issues researcher might miss.
- Protects vulnerable populations: IRB specifically assesses protections for minors, prisoners, cognitively impaired; researcher cannot unilaterally decide to conduct high-risk research on vulnerable populations.
- Reduces liability: IRB approval demonstrates researcher followed ethical oversight, protecting both subject and researcher if adverse events occur.
- Enables subject recruitment: many subjects are more willing to participate if research has institutional ethics approval; IRB approval signals legitimate, ethical research.
- Ongoing monitoring: annual continuing review ensures research continues to meet ethical standards; IRB can require protocol changes if new risks emerge.
- Standardized across institutions: most IRBs follow federal regulations (45 CFR 46), creating consistency in ethical standards.
- IRB approval does not guarantee research is actually ethical—IRB approval is necessary but not sufficient. A poorly designed study with unjustifiable risks might satisfy IRB requirements yet be unethical. IRB approval only addresses federal regulatory compliance, not all ethical concerns.
- Variability in IRB rigor: some IRBs conduct thorough review, others are cursory. No federal accreditation of IRBs; standards vary across institutions.
- Slow review process: IRB review can delay research 1-3 months or longer; creates tension between ethics oversight and research urgency (especially problematic during pandemics or public health emergencies).
- Researcher burden: completing IRB protocol application is time-consuming (20-100 hours for complex research); creates barrier for some researchers, especially in low-resource settings.
- Limited expertise in emerging fields: IRBs may lack expertise in novel research areas (e.g., AI/machine learning, blockchain, large-scale genomic research) and may inconsistently evaluate emerging risks.
- Vulnerable population protections not always effective: IRBs may miss subtle coercion or exploitation in vulnerable population research.
- International research complications: IRB standards vary globally; researcher conducting international studies must navigate multiple ethics committees with different requirements.
Frequently asked
Does my research require IRB review? How do I know if I'm exempt?
Almost all research involving human subjects requires IRB review. Truly exempt research is rare and limited to: (1) research using de-identified existing data (no identifiers, no way to link data back to individuals); (2) research using publicly available information without identifiers; (3) some quality improvement activities (but not if findings will be published or contribute to scholarly knowledge—then it is research requiring review). If unsure, contact your institution's IRB office—they can advise. Do not assume your research is exempt without explicit confirmation from IRB; proceeding with research that should have been reviewed can invalidate data and result in institutional sanctions. When in doubt, submit for review; IRB can quickly determine exemption status.
How long does IRB review typically take, and can I begin enrollment before approval?
Timeline depends on review type: EXEMPT DETERMINATION: 1–2 weeks; EXPEDITED REVIEW: 2–4 weeks; FULL BOARD REVIEW: 1–3 months (depends on IRB agenda, protocol complexity, revisions needed). Some institutions allow longer waits during high-volume periods. Do NOT begin subject enrollment before receiving written IRB approval. Any data collected before approval may not be usable, and your institution risks regulatory sanctions. Plan accordingly: submit protocol to IRB well in advance of intended study start date (typically 2–3 months buffer). If research is urgent (e.g., pandemic response), some IRBs can expedite review; contact IRB office to discuss options.
What happens if I want to change my protocol after IRB approval? Do I need to get approval for the change?
ANY material change to an approved protocol requires IRB approval before implementation. Material changes include: (1) changes to study procedures (adding a procedure, changing dose, altering duration); (2) changes to study population (e.g., lowering age limit, adding prisoner population); (3) changes to informed consent (revising risk descriptions, adding new risks, changing compensation); (4) changes to data handling (longer retention, secondary use, sharing with outside researchers). Minor administrative changes (e.g., correcting typo in protocol, updating researcher address) may not require approval; contact IRB office for clarification. Submit protocol amendment to IRB describing change and justification. IRB reviews amendment (typically expedited process, 1–2 weeks) and either approves change, approves with conditions, or requests modifications. You may not implement change until IRB approves.
What should I include in my IRB protocol application to avoid delays and revision requests?
Submit a complete protocol addressing all IRB review criteria: (1) RESEARCH QUESTION: Clear, specific statement of what you are studying and why (purpose and significance). (2) STUDY DESIGN: Detailed description of what subjects will do—procedures in chronological order, time commitment, frequency of visits. (3) SUBJECT POPULATION: Size (sample size with justification), age range, inclusion/exclusion criteria. (4) RISKS AND BENEFITS: Describe all foreseeable risks (physical, psychological, privacy, economic, social); for each risk, describe mitigation strategies. Describe benefits (if any) to subjects and potential benefits to science/medicine. (5) INFORMED CONSENT: Attach draft consent form addressing all required elements (purpose, procedures, risks, benefits, confidentiality, withdrawal rights, researcher contact, IRB contact). Describe consent process (will you discuss in person? How will you assess understanding?) (6) CONFIDENTIALITY: How will identifiable data be handled? Who has access? How long retained? Will data be de-identified? How will biological samples be stored? (7) RESEARCHER QUALIFICATIONS: Your CV demonstrating research experience; for studies of vulnerable populations, describe any special training. (8) IRB CHECKLIST: Complete IRB's own submission form/checklist. Do not leave items blank; if not applicable, state 'N/A' with brief explanation. Contact IRB staff before submission for guidance or to discuss complex issues. Submit all attachments and forms together; incomplete submissions delay review.
My research is minimal-risk observational study of behavior in public places. Do I still need IRB review?
Depends on specific characteristics. Minimal-risk OBSERVATIONAL research with NO identifiable information (you do not collect/record identifiers, cannot link observations to individuals) and involving only observation of publicly observable behavior is often exempt from review. Example: sitting in a mall and observing crowd flow patterns without recording faces or identifying individuals. However, if you collect ANY identifying information (recording faces, asking names, noting which individuals you observed), or if you ask questions (not mere observation), IRB review is required. If unsure, submit description to IRB office; they can quickly determine exemption status. Do not assume observation without identifying data is automatically exempt—context matters.
Sources
- U.S. Code of Federal Regulations, Title 45, Part 46: Protection of Human Subjects. Office of the Federal Register. link ↗
- U.S. Department of Health and Human Services, Office for Human Research Protections. (2016). Federalwide Assurance (FWA) for Protection of Human Subjects. Policy on IRB composition and review procedures. link ↗
- National Institutes of Health. (2020). Institutional Review Boards Frequently Asked Questions. Office of Science Policy. link ↗
How to cite this page
ScholarGate. (2026, June 3). Institutional Review Board: Structure, Function, and Protocol Review. ScholarGate. https://scholargate.app/en/research-ethics/institutional-review-board
Which method?
Set this method beside its closest kin and read them side by side — the library lays the books on the table; the choice is yours.
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- Declaration of HelsinkiResearch Ethics↔ compare
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- Research Integrity PrinciplesResearch Ethics↔ compare