Review of Research Involving Children/Minors

IV.10

 

 

Review of Research Involving Children/Minors

 

 

 

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Objective

To safeguard the interests of children who are participants in research and to protect them from harm, special regulatory considerations apply for reviewing the research and special conditions must be met prior to approval.  This Policy/Procedure describes the process by which the Committee for the Protection of Human Subjects (CPHS) members review protocols involving children and minors to ensure compliance with regulatory requirements and to protect children participating in research.

 

Policy/Procedure

I.              The CPHS must classify research involving children into one of four categories and document their discussions of the risk and benefits of the research study. The four categories of research involving children that may be approved by the CPHS based on degree of risk and benefit to individual participants, are as follows:

 

A.     Research not involving greater than minimal risk to the child (examples: urinalyses, obtaining small blood samples, EEGs, allergy scratch tests, minor changes in diet or daily routine, and/or use of standard psychological or educational tests). The CPHS may approve the research only if the CPHS finds that adequate provisions are made for soliciting the assent of the children and permission of their parents, or legal guardians

 

B.     Research involving greater than minimal risk, but presenting the prospect of direct benefit to an individual participant. Research in this category is approvable provided:

1.      The risk represents a minor increase over minimal risk;

2.      The relationship of risk to benefit is at least as favorable as any available alternative approach

 

C.     Research involving greater than minimal risk with no prospect of direct benefit to individual participants, but likely to yield generalizable knowledge about the participant's disorder or condition. Research in this category is approvable provided:

1.      The risk represents a minor increase over minimal risk; and

2.      The intervention or procedure presents experiences to participants that are reasonably commensurate with those inherent in their actual or expected medical, dental, psychological, social, or educational situations; and

3.      The intervention or procedure is likely to yield generalizable knowledge about the participant’s disorder or condition that is of vital importance for the understanding or improvement of the participant’s disorder or condition.

 

D.     Research that is not otherwise approvable, but which presents an opportunity to understand, prevent, or alleviate a serious problem affecting the health or welfare of children. Research that is not approvable under 45 CFR 46.404, 46.405, or 46.406 may be conducted or funded by DHHS provided that the CPHS and the Secretary of DHHS, after consultation with a panel of experts, finds:

1.      That the research presents a reasonable opportunity to further the understanding, prevention, or alleviation of a serious problem affecting the health or welfare of children; and

2.      That the research will be conducted in accordance with sound ethical principles

 

II.           Children who are wards of the State or any other agency, institution, or entity can be included in approved research only if it is either:

 

A.     Related to their status as wards; or

 

B.     Conducted in schools, camps, hospitals, institutions, or similar settings in which the majority of children involved as participants are not wards.

 

III.         If the clinical investigation is approved under 45 CFR §46.409(a) {FDA: 21 CFR §50.56(a)} the CPHS must require appointment of an advocate for each child who is a ward. [45 CFR §46.409(b)] [21 CFR §50.56(b)]

 

A.     The advocate will serve in addition to any other individual acting on behalf of the child as guardian or in loco parentis.

 

B.     One individual may serve as advocate for more than one child.

 

C.     The advocate must be an individual who has the background and experience to act in, and agrees to act in, the best interest of the child for the duration of the child’s participation in the research.

 

D.     The advocate must not be associated in any way (except in the role as advocate or member of the CPHS) with the research, the investigator(s), or the guardian organization.

 

IV.        The CPHS must determine that adequate provisions have been made for soliciting the assent of children and the permission of their parents or guardian.

 

A.     The CPHS must determine for each protocol – depending on such factors as the nature of the research and the age, status, and condition of the proposed participants – whether all or some of the children are capable of assenting to participation taking into account the ages, maturity, and psychological state of the children involved.

 

B.     The CPHS should determine that if assent is sought, the information/explanation of the proposed research procedures are in a language that is appropriate to the child’s age, experience, maturity, and condition. This should include a discussion of any discomforts or inconveniences, or if the child will be required to spend time in an unfamiliar place.

1.      Verbal assent is to be obtained from children under the age of 7 whenever possible

2.      Assent documents are signed by participants 7 to 11 years of age provided the child is mature enough to understand the planned intervention.

3.      Generally, the child's veto of participation is sufficient to make the child ineligible for inclusion in the study. However, the parent or guardian, with CPHS and physician approval, may override the veto if the intervention will benefit the child.

4.      The PI may not approach the child to assent to the research study until the parents or legal guardians have given written permission.

5.      When the research offers the child the possibility of a direct benefit that is important to the health or well-being of the child and is available only in the context of the research, the CPHS may determine that the assent of the child is not necessary.

6.      When research involves the provision of experimental therapies for life-threatening diseases such as cancer, however, CPHS should be sensitive to the fact that parents may wish to try anything, even when the likelihood of success is marginal and the probability of extreme discomfort is high. Should the child not wish to undertake such experimental therapy, difficult decisions may have to be made. In general, if the child is a mature adolescent and death is imminent, the child's wishes should be respected.

7.      For some research activities, the CPHS may require that either a CPHS member, research intermediary or an advocate for the child be present during the assent and permission procedures to verify the child's understanding and to support the child's preferences. The CPHS may also require that the parent(s) or a close family member be present during the research, especially if a young child will be exposed to significant discomfort or inconvenience, or if the child will be required to spend time in an unfamiliar place.

8.      Should the CPHS have questions or concerns it should consult legal counsel about the applicability of any state laws affecting consent for the proposed research.

 

C.     Parental Permission documents are signed by parents, or the legally appointed guardian, of children under age 18. Consent of one parent is sufficient if research involves minimal risk; consent of both parents is necessary if the research involves more than minimal risk. However, if one parent is deceased, unknown, incompetent or reasonably unavailable, or if one parent has legal responsibility or custody of the child, one parent consent is acceptable.

1.      The CPHS must determine for each protocol whether the permission of both parents is necessary, and

2.      The conditions under which one parent may be considered “not reasonably available”.

3.      Parental permission may sometimes be insufficient to protect the child's interests particularly when the interests of one child conflict with those of a sibling or other relation.  In such cases, CPHS may seek a legal guidance to clarify authority.

 

 

Definitions:

Assent – A child’s affirmative agreement to participate in research. Mere failure to object should not, absent affirmative agreement, be construed as assent.

                                               

Children – Persons who have not attained the legal age for consent to treatment or procedures involved in the research, under the applicable law of the jurisdiction in which the research will be conducted.

                                

Emancipated Minor – A legal status conferred upon persons who have not yet attained the age of legal competency as defined by state law, but who are entitled to treatment as if they had by virtue of assuming adult responsibilities, such as self –support, marriage or procreation.  Those who have had the disabilities of minority removed for limited or general purposes by the State of Texas.

                       

Guardian –  An individual who is authorized under applicable state or local law to give permission on behalf of a child to general medical care.

                                               

Permission  The agreement of parent(s) or guardian to the participation of their child or ward  in research.

                                               

Parent - a child’s biological or adoptive parent.

 

 

Applicable Regulations and Guidelines

21CFR 50 ( http://www.access.gpo.gov/nara/cfr/waisidx_04/21cfr50_04.html )

21CFR 56 ( http://www.access.gpo.gov/nara/cfr/waisidx_04/21cfr56_04.html )

38CFR 16 ( http://www.access.gpo.gov/nara/cfr/waisidx_04/38cfr16_04.html )

45CFR 46 ( http://www.access.gpo.gov/nara/cfr/waisidx_04/45cfr46_04.html )

ICH E6 ( http://www.ich.org/MediaServer.jser?@_ID=482&@_MODE=GLB )

IRB Guidebook: Chapter. 6 ( http://www.hhs.gov/ohrp/irb/irb_chapter6.htm#g4 )

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Updated 5/2007, Report broken links