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FAQ - Definitions


What is Research for purposes of compliance with the federal regulations protecting human subjects?  The relevant DHHS regulations are 45 §46.102 Definitions. (d) Research means a systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalizable knowledge. Activities which meet this definition constitute research for purposes of this policy, whether or not they are conducted or supported under a program which is considered research for other purposes. For example, some demonstration and service programs may include research activities.


What is the definition of a Human Subject? (f) Human subject means a living individual about whom an investigator (whether professional or student) conducting research obtains

(1) Data through intervention or interaction with the individual, or
(2) Identifiable private information


What is the difference between intervention and interaction?

Intervention includes both physical procedures by which data are gathered and manipulations of the subject or subject's environment that are performed for research purposes.

Interaction includes communication or interpersonal contact between the investigator and subject that are performed for research purposes.

Observation is neither an intervention nor an interaction.


Who is eligible to be a Principal Investigator?

Currently any faculty or staff employee or regular student of GVSU may serve as a Principal Investigator (PI).

  1. If the PI is a student, there must be a regular faculty member who serves as research advisor to the project and assumes primary responsibility for compliance with all relevant requirements, polices and procedures. The status of student PIs is currently under administrative review at GVSU.
  2. Researchers not otherwise affiliated with GVSU must have a regular GVSU faculty member as co-PI, or be an approved investigator operating under an approved IRB Authorization Agreement.
  3. All PIs must have their proposed research protocols approved by their unit's authorizing official (AO) before it will be reviewed by the HRRC. Some units require both the faculty research advisor's approval and the unit head's approval so students should check with their research advisor to be certain of what they need. All approvals are electronic signatures made in the protocol file on IRBNet.


What is the difference between research, therapy, experimentation and innovation?

A physician may, as part of therapy practice of medicine, lawfully prescribe a different dosage for a patient, or otherwise vary the conditions of use from those approved in the package insert, without informing or obtaining the approval of the FDA. (37 Fed. Reg. 16503 (Aug. 15, 1972)). In addition, when a clinician departs in a significant way from standard or accepted practice, the innovation does not, in and of itself, constitute research. The fact that a procedure is "experimental," in the sense of new, untested or different, does not automatically place it in the category of research. (44 Fed. Reg. 23,192, 23,193 (1979)).

The DHHS regulations (45 CFR § 46) apply to research involving human subjects conducted by DHHS or supported in whole or in part by DHHS.

The FDA regulations (21 CFR §50 & § 56) apply to all research involving products regulated by the FDA, including research and marketing permits for drugs, biological products, or medical devices for human use, food and color additives, or electronic products. Federal funds do not need to be involved. When research involving products regulated by the FDA is funded by DHHS, both DHHS and FDA regulations apply. For FDA purposes, off label use does not constitute research unless data collected will be used to support an application to FDA.  21 CFR § § 50 & 56 only applies to research regulated by FDA, which includes clinical investigations that support applications for research or marketing permits for products regulated by the FDA.