Attachment F- HSRB

DEPARTMENT OF HEALTH & HUMAN SERVICES
_______________________________________________________________________________________________________

Memorandum
Date

March 2, 2012

From

Chair, NIOSH IRB (HSRB)

Subject

Report of NIOSH HSRB – Protocol No. HSRB 12-HELD-NR01 “ROVER: A National Survey of
Assistance Dog Providers” Non-Research Determination Documentation

To

Oliver Wirth, Ph.D. – PI
Project Officer, ECTB, HELD, NIOSH
Through: /Chief, ECTB, HELD, NIOSH
/Associate Director for Science, HELD, NIOSH____ ____
General Comments and IRB Actions
Your E-mails (dated 2/24/12 and 3/2/2012) have made mention of two surveys; one of Veterans and
one of Assistance Dog Providers. A draft protocol has been provided for the survey of Assistance
Dog Providers. A comparable protocol was not provided for the survey of Veterans. From the
information provided, these surveys appear to be independent. Since the information provided
regarding the survey of Veterans is inadequate to make a determination, I can only make a
Research/Non-Research determination on the survey of Assistance Dog Providers.
I will need more information (comparable to the Provider protocol) to make Research/Non-Research
determination on the survey of Veterans.
I have reviewed the attached draft protocol “ROVER: A National Survey of Assistance Dog
Providers” submitted to the IRB on February 24, 2012. The activity described is a survey of
assistance dog providers in the U.S. for the purpose of collecting information about the services they
provide for Veterans. The objectives are to obtain information on agency structure, goals, target
population, and services provided to Veterans including strategies they have used to address issues
related to return to work.
I have determined that the proposed survey, as described, does not involve human subjects. HHS
Human Research Protections Regulation, 45 CFR 46.102 (F) defines a human subject as “a living
individual about whom an investigator conducting research obtains data through intervention or
interaction. . . or personal private information.” As described, the proposed project will not be
obtaining any information “about” an individual. The description provided indicates that proposed
questionnaires only address questions about facilities and the services they provide.
Therefore, the proposed survey of assistance dog providers does not require review by the NIOSH
IRB.

cc:
HSRB 12-HELD-NR01