Safeguards for Vulnerable Subjects

You must provide appropriate safeguards if you plan to recruit subjects from the following vulnerable groups: 

        Children
A child is anyone under the age of majority in your state. A child's parent or legal guardian must accompany a child during the informed consent process. A written assent should be obtained from children 7 years or older unless assent is waived by the IRB. The child should be given an opportunity to decide, independently, whether or not to participate in the study. If the child agrees, his/her signature (or printed name) indicates assent. In Alabama and Nebraska, 18 year olds are considered children.

Economically Disadvantaged
The site must ensure that the compensation is not presented in a manner that may unduly influence a subject to participate or that is coercive. Payment must not be contingent upon completion of the entire study. There must be a plan to pro-rate payments. Any compensation or bonus for completion must be reasonable and not so large as to influence the subjects to enroll or stay in the study.

Educationally Disadvantaged
For an individual who may have trouble comprehending the written ICD, the person conducting the consent discussion must review each section of the ICD with the potential subject and pose questions after each section to ensure an adequate understanding. For an illiterate subject, an independent witness must also be present during the presentation of and signing of the ICD and must also sign the ICD. An independent witness must not be an employee of the investigator or research site.

Employees/Family Members
Measures must be taken to ensure the confidentiality of an employee's study-related medical records. Additionally, no action can be taken against an employee based on information to which an employer would not otherwise be entitled but obtains because of an employee's participation in a study. An employee who participates in a research study must be treated as other subjects and must be able to decide not to participate or to discontinue study participation without any impact on his/her employment status. The Board requires that each employee sign a non-coercion addendum prior to the subject's participation in the study. If consistent with the protocol and if you indicate on the Research Site Submission form that you plan to enroll employees, Schulman will send a Non-Coercion Addendum with the initial approval document. If, after receiving your initial approval documents, your site decides to enroll an employee, please send a written request for a Non-Coercion Addendum, along with safeguards before enrolling the employee in the study. "Employee" refers to either an employee or an employee's family member who is participating in a research study.

Physically Impaired
An individual with physical impairment(s) (e.g., visual, hearing, speech) that would prevent normal communication, and who is unable to read and/or sign the ICD, must have an independent witness present during the informed consent process. The independent witness must also sign the ICD. An independent witness must not be an employee of the investigator or research site.

Life Threatening Condition/Seriously Debilitating Illness
An individual with a life-threatening condition must be told of alternative treatments and that participation in a research study may not benefit his/her present medical condition. The Investigator must confirm that the subject understands this information.

Mentally Disabled/Cognitively Impaired
An individual who is not competent to understand verbal and written information and provide informed consent must have a Legally Authorized Representative (LAR). The law of the state where the site is located defines who has legal authority to act as an LAR. The LAR must sign the ICD on behalf of the subject.

Non-English Speaking Subjects
If the site consents a non-English speaking subject, it must use an IRB approved translated informed consent document. The site must also provide someone who is capable of answering questions in the language of the non-English speaking subject throughout the study.

Nursing Home Residents
Each state has a "Nursing Home Bill of Rights" of which the investigator, study staff, subject and LAR, if appropriate, must be fully aware.

Pregnant Women
A pregnant woman must be fully informed regarding the foreseeable impact of the research on the fetus or resultant child. In addition, the individuals engaged in research must have no part in any decisions as to the timing, method, or procedures used to terminate a pregnancy and must have no part in determining the viability of the fetus. No inducements, monetary or otherwise, can be offered to terminate a pregnancy.

Prisoners
Schulman does not review studies in which prisoners are the targeted population.