A more extensive application for the rule was considered safer for the university, though it is not clear to me that non grant funded research would be examined by any federal agency or that anything wouldhappen to the university if non grant funded research didn't comply with the guidelines. So that is problem number one. I don't think the guidelines should have been extended to non grant funded research, though the university should certainly support ethical research, but I am more concerned that that extension is made to appear a federal requirement when it is not. It is a university decision, and therefore subject to university policy making. We could therefore establish a policy on research ethics that applied better to qualitative research if we chose to, for those not funded by grants.
Exempt research includes observation in public settings.
In past experience when I tried to comply with this rule by having students submit qualitative research proposals, for class projects, the applications were returned to us, as out of the bailiwick of the university office. They had no way of dealing with qualitative research. Given that we focus our research in the field and our proposals come out int he middle of the work and not at the beginnign, and we are being forbidden to start research without giving the office our proposals, if we follow the rules, we cannot do qualitative research on campus. The only change I have been able to ascertain in the federal guidelines is the requirement for training before research, but it is not clear to me that this requirement is for non grant funded researchers, I think the university probably followed its earlier pattern and extend the rules from grantees to non grantees. If so, it could reverse the decision if it sees that there is a serious problem with the policy.