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Tutorial 5: Plan for Action

DEBATE OVER IRB and Action Research

When action research is part of a university program, how does the Institutional Review Board (IRB) handle action research proposals?

All universities set up review boards to oversee the research done by researchers and graduate students at their universities.  This was done to protect research subjects and the university from claims of abuse in the name of research.  Universities vary in the way they approach ethical issues in action research. Action research is done with co-researchers, not subjects, and is done over time, continually evolving.  These aspects of action research do not fit with the assumptions of the traditional review process.   Oversight of action research is sometimes reviewed through the formal channels of IRB, but it is also reviewed outside of the formal IRB review process, or through special committees of the IRB. 

We posted a poll to invite readers to share what happens at their university. The poll that was posted in an earlier version of this site closed after 40 responses with these results: 

  •   8.7%   Ethical issues for action research are handled outside of the formal university IRB process.

  •   8.7%    There is a special process for IRB review of action research

  • 78.3%    Action researchers submit once for IRB approval in the same way as for other forms of research

  •   4.3%    Action Researchers need to submit designs for each cycle of action research


1) Arguments for why IRB is not necessary for action research:

Some universities have accepted action research as falling outside of the need for a formal IRB review. Here are some of the arguments for this position.

This came from The American Educational Research Association (AERA ) in 2011:
AERA along with the Federation of Associations in Behavioral and Brain Sciences (FABBS) and the Consortium of Social Science Associations (COSSA), is leading an effort across research associations and organizations to examine the many aspects of changes intended to improve practices for human research protection and promote research.
Proposed rulemaking changes for the U.S. Federal Regulations for the Protection of Human Research Participants:

In late July, the U.S. Department of Health and Human Services (HHS), in coordination with the Office of Science and Technology Policy (OSTP), issued an advance notice of proposed rulemaking (ANPRM) changes to federal regulations governing human research protections (45CFR46, Subpart A). The ANPRM seeks to protect research participants while advancing essential research. The potential changes are far-reaching ranging from seeking to remove low-risk research with adult populations from consideration by Institutional Review Boards (IRBs) to introducing a new category of excused research that would not require IRB review but where otherwise exempt research would be registered and where research that only involves informational risk would not be reviewed by IRBs but could be alternatively governed by mandatory standards of data security.

Quoted from a recent ethics blog from the Action Research Journal (Sage) written by Mary Brydon-Miller which reviews a book by Zachary M. Schrag:
Ethical Imperialism: Institutional Review Boards and the Social Sciences, 1965--2009

As Schrag points out, the IRB system was designed to address issues facing medical and behavioral sciences and is based on four assumptions:

1. Researchers know more about their subjects’ condition than do the subjects themselves.
2. Researchers begin their work by spelling out detailed protocols explaining what hypotheses they will test and what procedures they will employ to these hypotheses.
3. Researchers perform experiments designed to alter subjects’ physical state or behavior, rather than simply gathering information through conversation, correspondence, and observation.
4. Researchers have an ethical duty not to harm their subjects.

But while these assumptions may apply to medical and some forms of psychological research, they don’t do a good job of recognizing and addressing the ethical issues facing researchers in other social science fields, and certainly don’t begin to respond to the ethical implications of action research where we acknowledge that our community partners know more about their experience than we do, where we co-generate meaningful research questions that may change as the process moves forward, and where we create knowledge together through a variety of methods. We do agree with not causing harm but action researchers are improving their skills and supporting the development of others in ways that are not usually ethically problematic.
Here are some additional arguments:


  1. The subject of action research is the researcher and, as such, the person is in full control and is aware of any risks and gives full consent.

  2. The actions taken are part of the person's job, and the workplace has its own norms, rules, and regulations that determine what is and is not a part of the work. The action researcher needs to get approval for all actions from their immediate supervisors.

  3. Action researchers do examine data to determine the outcome of their action research. Ethical issues have to be followed for this process. Supervisors of action research need to make these assessments and refer anything that approaches a risk (outside of what would normally be done as part of their job) to IRB for further discussion.

  4. Action research when done in the context of coursework is exempt from IRB review. However, the importance of sharing the results of action research does then involve IRB, but this could be amended.

  5. The workplace has its own ways of dealing with researcher processes by employees, and when these are followed, there may be no need for further review.

Here is a summary of some of the tensions that make the match between IRB designed process for experimental research and the needs of action researchers conflict:










2) IRB review of action research:

In some universities, action researchers apply for research through the IRB process. If this is the case with your university, how do you handle the constantly evolving nature of action research? And how long does it take to get this approval? Is there a special team of reviewers that understands the needs of action researchers?  Here are some of the replies that were posted in response to these questions. 

Lehman College/City University of New York. Action research projects must be reviewed by our campus IRB. When the research takes place in schools, it usually also requires the approval of the New York City Department of Education's equivalent of the IRB as well as the school's principal. Lehman's IRB convenes several times a year, so proposals must meet deadlines. Approval can take 2-3 months from proposal to approval, so planning ahead is essential. Full IRB approval is only required for research that entails interventions, however. Many action research projects study regular practice, so Lehman College's IRB does allow for expedited or exempt reviews. These are permitted when no research entails extraordinary interventions, and the researcher is studying regular practice and its impact on students and/or teachers. Since K 12 students are minors they are considered a vulnerable population, so researchers may apply for expedited but not exempt status. Expedited and exempt research projects must still submit a proposal to the IRB. The IRB committee (a standing committee comprised of faculty) will determine whether the project is eligible for this status.

Before submitting a proposal for IRB approval researchers must pass a test through CITI programs. This consists of a tutorial on the history of human subjects research followed by a quiz. This eligibility must be renewed every two years in order to be permitted to continue conducting research. Approved researchers are on file with the CUNY Research Foundation. Each CUNY campus has its own IRB.


3) Alternate approaches used by IRB to review action research:

In some cases, an IRB might create a special committee to deal with the evolving nature of action research. Students would be able to submit and have a review completed in a small number of days. This process could be repeated for each cycle of research as is unlikely that a researcher knows where the path of understanding will lead.  

The issue of voluntary participation conflicts with the development of teaching practices that are not voluntary.  A teacher has both the right and responsibility to use student actions as a form of assessment of their learning.  Michael Owen of Brock University explores many of these issues in his thoughtful article, "Conflict and Convergence: The Ethics Review of Action Research."  He explores some of the dilemmas involved in IRB review of action research and the dialogue that is needed to resolve them. He seems to assume that action researchers are conducting a single cycle of action research rather than focusing on the iterative ongoing nature of action research. The problem comes from characterizing action research as a way to do work over time. In this case, one is always collecting evidence.


The discussion in "Surpassing Ourselves: An Inquiry into the Nature and Implications of Expertise" by Bereiter and Scardamalia makes the argument for a process similar to action research as a way of developing generative expertise. It can be argued that action research sets up a way to work that, while sensitive to the rights of others with respect to research, requires a very different form of review than the traditional IRB is set up to offer. Action research is a way of learning --developing progressively deeper understandings-- of how to work, and in doing this how to develop generative expertise.  Learning from and through work requires one to understand what is involved in ethical behavior well beyond the time at a university. 

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