To the Editor:

Editor's Note: Linda Shopes (Pennsylvania Historical and Museum Commission) and Donald Ritchie (U.S. Senate Historical Office)—who represented the AHA and the Oral History Association, respectively, in discussions with the Office for Human Research Protection—write in response to E. Taylor Atkin's letter.

Institutional Review Boards were established to prevent the very real physical and mental harm that some biomedical and behavioral research had inflicted on human subjects. Without much specific guidance from the federal government, IRBs have increasingly extended their jurisdiction to cover all forms of research involving human interaction, including oral history interviews, even though most IRBs lacked sufficient representation in the humanities to make informed judgments about their research methodologies.

The U.S. Office for Human Research Protection (OHRP) has now affirmed in a policy statement—developed by the AHA and the Oral History Association—that federal regulations were designed for scientific and social scientific research projects that use standard questionnaires with generally anonymous sources to produce quantitative information for "generalizable knowledge." Since that's not the way most oral historians operate, the type of research they do is generally excluded from IRB review. Research that does meet the regulatory definition, including much of the work done in the social sciences, will continue to fall under IRB scrutiny.

In agreeing to the policy statement, the OHRP took into account the ethical and professional standards that oral historians have formulated and promoted. These are contained in the Oral History Association's Principles and Standards and Evaluation Guidelines (available online at http://omega.Dickinson.edu/organizations/oha/pub_eg.html), which are also referred to in the "Statement on Interviewing for Historical Documentation" in the AHA's Statement on Standards of Professional Conduct. The exclusion of oral history from IRB review does not lessen the ethical requirements of historical interviewing, but shifts the burden back onto the shoulders of Professor Atkins and others who use and teach oral history methodology, and allows the IRBs to concentrate on the job they were meant to do.

—Linda Shopes, Pennsylvania Historical and Museum Commission
—Donald A. Ritchie, U.S. Senate Historical Office