The Oral History Debate: Is it Research?

In recent years, as Institutional Review Boards (IRBs) have faced increasing governmental scrutiny they have struggled to apply the letter of the law to social science research in ways that are not overly restrictive and onerous to researchers. One such area of social science research that has been contentiously debated is in the field of oral history. For years, oral historians have argued that much of the work they perform should not be categorized as research, as the federal government defines research. 45 CFR 46.102(d) defines research as "a systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalizable knowledge." Oral historians have argued that interviews conducted with individuals about events of the past do not fall into this definition of research since they are designed to document a specific historical event or the experiences of individuals and are not intended to draw conclusions or contribute to generalizable knowledge. The Oral History Association sent a letter and proposed policy to the Office of Human Research Protections (OHRP) in August of 2003 making just such an argument.

The OHRP responded in September of 2003 with a letter concurring with the proposed policy, which stated that oral history interviews do not fall within the federal definition of research in that, generally, they do not serve the purpose of contributing to generalizable knowledge. Essentially, OHRP's concurrence indicates that oral history interviewing work does not in some cases require IRB review. OHRP has not yet issued a formal policy statement, however, and clearly indicates that the agency has not accepted the policy put forth by the Oral History Association as its own.

In December of 2003, at the Applied Research Ethics National Association (ARENA) annual meeting in Washington, DC, an OHRP representative, Michael Carome, discussed the current status of the oral history debate. The discussion outlined three principles for evaluating oral history activities, all of which rest upon a decision as to whether generalizable knowledge will be created.

1. Oral history activities, such as open ended interviews, that ONLY document a specific historical event or the experiences of individuals without an intent to draw conclusions or generalize findings would NOT constitute "research" as defined by 45 CFR 46.
   
   Example: An oral history video recording of interviews with holocaust survivors is created for viewing in the Holocaust Museum. The creation of the video tape does NOT intend to draw conclusions, inform policy, or generalize findings. The sole purpose is to create a historical record of specific personal events and experiences related to the Holocaust and provide a venue for Holocaust survivors to tell their stories.
2. Systematic investigations involving open-ended interviews that are designed to develop or contribute to generalizable knowledge (e.g., designed to draw conclusions, inform policy, or generalize findings) WOULD constitute "research" as defined by 45 CFR 46.
   
   Example: An open ended interview of surviving Gulf War veterans to document their experiences and to draw conclusions about their experiences, inform policy, or generalize findings.
3. Oral historians and qualitative investigators may want to create archives for the purpose of providing a resource for others to do research. Since the intent of an archive is to create a repository of information for other investigators to conduct research as defined by 45 CFR 46, the creation of an archive WOULD constitute research under 45 CFR 46.
   
   Example: Open-ended interviews are conducted with surviving Negro League Baseball players in order to create an archive for future research. The creation of such an archive would constitute research under 45 CFR 46 since the intent is to collect data for future research.

The Penn State IRBs concur and have adopted this guidance information.

If you have questions about the three principles and how your project may be categorized, please do not hesitate to contact the ORP to discuss your work with one of the IRB administrators.