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Research conducted or supported by a DoD Component requires additional information to be submitted to the IRB with the research application. Investigators should complete and attach a completed DoD Supplement Form to the Documents and Attachments page of the ERICA application.

A Department of Defense (DoD) Component is the Office of the Secretary of Defense, the Military Departments, the Chairman of the Joint Chiefs of Staff, the Combatant Commands, the Office of the Inspector General of the Department of Defense, the Defense Agencies, the DoD Field Activities and all other organizational entities in the Department of Defense.

Additionally, investigators and IRB members need to be informed of the specific requirements for research that is conducted or supported by a DoD Component (e.g. through a contract, grant cooperative agreement or other arrangement).  This web page is intended for use by both the investigator and IRB members in order to comply with any required regulations.

The University of Utah IRB follows IRB SOPsIRB guidance, and DoD regulation when reviewing human subject research supported and regulated by the DoD. The University of Utah does not review a large number of studies involving the Department of Defense and those that have been reviewed by the University of Utah IRB have involved minimal risk. The following guidance describes the DoD regulations for reviewing studies that involve greater than minimal risk or has a special consideration(s) e.g., classified research, research with vulnerable populations, etc. that does not commonly occur at the University of Utah. The information below provides a brief overview of how the University of Utah IRB would review such studies. In conducting these reviews, the University of Utah IRB will refer to and follow the applicable Department of Defense regulations.

Additional Considerations for DoD Research


Vulnerable Populations in Department of Defense Research


Research involving pregnant women, prisoners and children that is conducted or supported by the Department of Defense is subject to DHHS Subparts B, C, and D. However, the DoD has supplemental guidance for these studies. Review the table below to determine the DoD requirements and IRB guidance for each vulnerable population.

Population

DoD Requirement

University of Utah IRB Guidance

Pregnant Women, Fetuses, and Neonates

  • For the purposes of applying Subpart B, the phrase “biomedical knowledge” must be replaced with “generalizable knowledge.”
  • The applicability of Subpart B has limited applicability for DoD studies. However, the University of Utah applies Subpart B to all studies involving pregnant women, neonates and fetuses. Therefore, the University of Utah IRB holds a stricter standard than the DoD provision.
  • Fetal Research must comply with US Code regarding the research on transplantation of fetal tissue. The University of Utah follows the regulations regarding the transplantation of fetal tissues. The DoD requirement is met.

Prisoners

  • Research involving prisoners cannot be reviewed by the expedited procedure.
  • When the IRB reviews research involving prisoners, at least one prisoner representative must be present for quorum.
  • The DoD allows epidemiological research under certain conditions. The University of Utah IRB allows this same category of research involving prisoners.
  • The guidelines for when a participant becomes a prisoner from the DoD are consistent with University of Utah IRB guidelines.
  • Research involving a detainee as a human participant is prohibited.
    • This prohibition does not apply to research involving investigational drugs and devices when the same products would be offered to US military personnel in the same location for the same condition.
  • Research involving prisoners of war is prohibited.

Children

The exemption for research involving survey or interview procedures or observation of public behavior does not apply to research with children except for research involving observations of public behavior when the investigators do not participate in the activities being observed. The University of Utah has the same stipulation.

Classified Research

For all Department of Defense conducted or supported non-exempt human subject research involving classified information (as defined in Executive Order 13526), additional requirements must be applied. The review of research involving classified information is rare and requires Secretary of Defense approval. Additional requirements are described in the Department of Defense Instruction 3216.02 13. It should be noted that VA conducted or supported non-exempt human subject research involving classified information is not permitted.

Multi-Centered Research

If you are the lead investigator/site for a multi-centered study, you have additional responsibilities for overseeing the activities at the University of Utah as well as the other sites participating in the study. To meet DoD requirements (SECNAVINST 3900.39D, section 6f), you must execute an agreement or statement of work with all collaborating sites that delineates each site's responsibilities. This document should include the following elements:

  • A brief description of the research
  • Specific roles and responsibilities of each site, including scientific and IRB review; recruitment of participants; and informed consent procedures
  • Plan for ongoing data and safety monitoring, reporting requirements, documentation retention, and compliance for the entire research project

If you are not the lead investigator for a multi-centered DoD study, ensure that you request a copy and sign the study's agreement/statement of work prior to initiating study procedures at the University of Utah.

International Research

If the DoD research is conducted in a foreign country, the investigators must submit verification of the local ethics review (i.e. approval to conduct research). The investigator must abide by the local laws, regulations and customs as applicable. For more guidance, please see the Investigator Guidance Series: International Research.

Guidelines and Policies

Note: This is not a comprehensive list of guidelines and policies for DoD research, but represents guidelines and policies commonly referenced for research reviewed at the University of Utah.