Some course activities are sufficiently research-related that they raise questions for faculty about whether or not they come under the province of the Institutional Review Board (IRB). In the spirit of trying to give guidance (not hard-and-fast rules), three broad categories of activities are suggested. They are based on the federal definition of research as "a systematic investigation (i.e. the gathering and analysis of information) designed to develop or contribute to generalizable knowledge."
Data are collected from students enrolled in a course for the purpose of demonstrating principles of science and/or behavior firsthand. Such demonstrations are public within the context of the class, the risks are known to be minimal, and students can choose not to participate or they may choose other options. Data are not collected for publication in scholarly journals or as a report disseminated outside the course. There are no restrictions about how long the demonstration lasts (one or more class periods), where the data are initially collected (during or outside class time), or how "well-known" the principle being demonstrated is (as long as it is sufficiently like known phenomena to assure that the risks are minimal). Category 1 activities do not need IRB contact (although nothing precludes a professor from seeking advice from the IRB).
This category, which includes students doing statistical analysis, may or may not need IRB approval; the following is suggested:
If students are enrolled in a course (such as research-methods), then they may be required to become involved as participants in class projects (just as they may be required to write papers, do oral presentations, take tests, etc.). The catalog and course syllabus would alert students to this fact, and students "agree" to this participation by enrolling in the course. Although this does not eliminate the possibility of "risk" to them, it is a matter of professional teaching ethics that govern such class assignments, rather than the research ethics considerations.
If, on the other hand, such students are asked to serve as researchers with non-class participants serving as subjects, then the interests of these non-class members takes precedence. If the project would readily fit under the exemption categories of the IRB, then the professor may seek "blanket" IRB approval in advance, based on a generic description of topics and/or methods that the professor will subsequently allow students to pursue. Otherwise, the project should be submitted under standard IRB procedures.
Students doing research under faculty guidance (e.g., thesis, independent study, tutorials) may or may not require IRB review. Consultation with the IRB is recommended where there is uncertainty.