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Is there a standard customary timeline for applying for IRB1 approval with an industry-funded project?

Should you apply for IRB approval first, then accept the funding for the project, or accept the funding for the project and then apply for IRB approval?

It seems the latter could be dangerous if IRB approval is not granted.


1 An IRB (Institutional Review Board), also known as an independent ethics committee or ethical review board, is a group that reviews and monitors research involving human subjects.

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First note that it's a question of institutional policy whether human subjects research that is not federally funded requires IRB review. The common rule requires that federally sponsored research receive IRB approval but does not require institutions to do IRB review for research not funded by the government. However, many universities require that all research involving human subjects receive IRB approval whether or not it is funded by the federal government.

Assuming that IRB review is required, it is critical that you not begin the actual research until after IRB approval has been obtained- starting without approval is a big no no.

Normally, IRB approval must be obtained before your institution enters into a contract with the funder or the grant is awarded. For example, at our institution, the restricted funds accounting office won't do the paperwork for a research contract involving human subjects research until the IRB approval has been granted. We are also not allowed to submit a proposal to a funding agency without (edited to clarify this) submitting the proposal to the IRB for approval. There's a good chance that your institution has a similar policy.

Even if your institution doesn't have a specific policy about this, you should not try to get your institution to enter into a contract before the IRB approval is granted. If for whatever reason the IRB approval is denied, then you would have gotten your institution into a contract that it can't fulfill.

If I was asked to take on a research contract involving human subjects and wanted to accept the funding, I would tell the funder, "Yes, I would like to accept this funding. However, I will have to get IRB approval (as well as other approvals) before the institution will enter into a formal contract."

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    Regarding your first paragraph, besides for university policy, it may also be a matter of journal policy if you plan to publish the work. – ff524 Oct 2 '14 at 1:42
  • I should have made it clear that I'm talking about IRB review in the United Stated on the common rule used by federal agencies. Other countries have their own standards for review of studies. – Brian Borchers Oct 2 '14 at 1:51
  • Interesting to hear your institute has a rule about this, mine does not. Are you saying that every time you want to write a proposal for grant funding, you need to have IRB approval? That seems pretty time consuming considering the weeks to months to get IRB approval, and the times being rejected from a grant – user-2147482637 Oct 2 '14 at 4:32
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    Actually, I should correct myself- for proposal submissions, the IRB proposal has to be submitted before our institution will send a proposal on to the funding agency. The IRB approval and funding agency review can go on at the same time. However, the funding agency (e.g. NSF) won't make an actual award until the IRB approval has been granted. For research contracts (they're inviting you to do the work for them), you need to have the IRB approval in place before the contract is agreed to. – Brian Borchers Oct 2 '14 at 13:48
  • See this web page from the NSF: nsf.gov/bfa/dias/policy/human.jsp – Brian Borchers Oct 2 '14 at 13:49

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