Being a cautious type I sent them an EMail explaining what I was doing and essentially saying 'I'm sure this doesn't fall under your jurisdiction, but please tell me I'm correct.' The wrote back and told me they must review it and that I couldn't proceed until it was approved.
A week of panic ensued. I cited the federal regulations saying, as I thought, that this kind of work was exempt. No, it just means that I don't need a 'full' IRB review, I could get an expedited one. Having envisioned months of delay and canceled plane reservations and a glowing red face I was enormously relieved to find that all it took was filling in a 13 page form, submitting my sabbatical proposal and the questionnaire I planned to use (still in draft form which a knowledgeable friend assured me was a no-no).
I submitted. I received a request for a minor correction and approval letters from each institution I planned to visit. Panic again - I don't have invitations from each institution. After a phone call I was told that the original emails of what I had might suffice (the text of the emails in my proposal wouldn't do). Several hours later, after a complex search hindered by my email program's not indexing archives automatically I sent off the information.
Last week I received the opinion that I was exempt and could proceed, but still under some reporting and updating strictures.
I'm not sure if there are any big lessons in this.
- Some would say I was a fool for asking.
- Others would curse the weird rules that make you jump through hoops to prove you don't fall under the rules.
- Others would say I should have expected it.