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From the OHA:

We encourage you to respond as a concerned oral historian, either by submitting the below statement in the comment box in the online form (link below), or offering your own thoughts and observations on the issues raised by the proposal. The comment period closes on October 26, 2011.  We are advised that high volume of response is most critical.  You can also submit your comments by mail to Jerry Menikoff at either jerry.menikoff@hhs.gov or Office of Human Research Protections, 1101 Wootton Parkway, Suite 200, Rockville, MD 20852. 

The online submission form has a 2000 character limit so we have drafted a brief version of the statement.  To view the statement in its entirety, click here.  We strongly encourage you to make your own comments, however, we have also provided the opportunity for you to copy and paste the text below onto the online comment form.

Click Here to Access Online Comment Form

Copy Text Below

1) Regarding whether “certain fields of study [such as history] whose methods of inquiry were not intended to or should not be covered,” we argue for full exclusion of oral history from the terms of the Common Rule.

a. Oral history research focuses on eliciting information about particular past experiences and suffers irreparable harm when forced into rubrics developed to treat subjects in a “generalizable” way as demanded by scientific research

b. Oral history research is built on open dialogue with interviewees and cannot be assessed properly within the IRB regulatory framework

c. The proposed “excused” category does not address our concerns.  It keeps oral history tied to inappropriate science frameworks and adds the burden of rules designed to prevent “information risk”

d. This is not a plea to be free of professional standards. The Oral History Association maintains its own Principles and Best Practices governing the conduct of oral histories in an ethically responsible way; but our standards are applied in fundamentally different ways than the scientific procedures and criteria administered by IRBs

2) The implications for oral historians in the proposed rules to limit “information risk” are also of concern.

a. Overregulation of the future use of archival or public-use data can inhibit our understanding of the past, including data that would hold scholars accountable for misuse of research subjects

b. Oral history protocols already mandate signed releases by interviewees, in which they state explicitly the terms by which the interview can be used in the future.

c. The federal proposal-and specifically the application of HIPAA rules to non-medical research-reflects the danger of a “one size fits all” approach

3) History and Oral History were never envisioned as falling under these rules. This review offers an opportunity to correct the misapplication of IRB authority.

The SLSA newsletter print edition is on its way, but here’s a sneak peek of one item and the full-length version of another.  Enjoy!

SLSA stalwart Bob Zieger shares “The Lessons of the Past,” his Labor Day address to the North Central Florida Central Labor Council in Gainesville.

Meanwhile, Bob Korstad offers up his keynote address from the spring 2011 SLSA-LAWCHA conference: “Searching for a Usable Past: Fifty Years of Writing Southern Labor History.”

If you are interested in proposing an SLSA event at next spring’s OAH/NCPH meeting in Milwaukee, please let me know by October 5th.

David Zonderman, Chair, SLSA Program Committee (david_zonderman@ncsu.edu).

For additional information on the submission process and requirements,

Dear Colleague:

The joint annual meeting of the Organization of American Historians and the National Council on Public History will be held Thursday, April 19 to Sunday, April 22, 2012, at the Frontier Airlines Center and Hilton Milwaukee-City Center in Milwaukee, Wisconsin. We encourage your organization to schedule a ticketed and/or non-ticketed function to be held during the convention.

TICKETED FUNCTIONS

OAH can sell tickets for your breakfast, luncheon, or dinner event through the preregistration form. If tickets are sold, OAH will make all of the necessary arrangements for food and room setup. And, if the information is received by October 15, 2011, we will list your ticketed events in our Annual Meeting Program.

NON-TICKETED FUNCTIONS/SESSIONS

OAH is also able to schedule sessions, committee meetings, or social functions for your organization. These functions will be assigned space by the OAH. However, groups sponsoring non-ticketed functions must arrange catering needs directly with the hotel following assignment of a room by the OAH. All food and/or beverages served at an event in the hotel must use the facility’s catering department. Again, requests for non-ticketed functions must be received by October 15, 2011 to guarantee publication in the Annual Meeting Program.

RESERVING SPACE AT THE MEETING

Please complete the Event Request Form for each function you wish to schedule. Requests will be handled on a first-come, first-served basis. A final confirmation of the event, including room assignment, will be emailed to you in January. If your event is a non-ticketed, catered function, your confirmation will include the name and telephone number of a catering contact at the hotel or convention center who will work with you directly.

TELLING LABOR’S STORIES IN THE SOUTH: A WORKSHOP ON PUBLIC ENGAGEMENT WITH LABOR HISTORY

Friday, October 28: 4:45 P.M. Pratt A; Session 28.

Sponsored by the Southern Labor Studies Association

PRESIDING: David Zonderman, North Carolina State University

• Engaging Public Schoolteachers in Southern Labor History: Lessons from the Teaching American History Program; Robert Korstad, Duke University
• Teaching and Writing Southern Labor History for Young Audiences; Scott Nelson, College of William and Mary
• Southern Labor History and Contemporary Political Debates: Writing and Publishing Op-Eds;David Zonderman, North Carolina State University

SOUTHERN LABOR STUDIES ASSOCIATION LUNCHEON

Saturday, October 29: 11:45 A.M.-1:30 P.M. Shula’s PDR; Session 41.

PRESIDING: Jennifer E. Brooks, Auburn University

John Bull Meets Jim Crow: Jamaican Guest Workers in the Wartime South

Cindy Hahamovich, College of William and Mary

Co-sponsored by the Southern Industrialization Project, and the

History Departments of the University of Maryland, College Park, and

Georgetown University.

To be followed by the Annual Members Meeting.

To register for this catered luncheon, send a check for $15.00, by October 10, made payable to

Georgia profs offer course to illegal immigrants (Atlanta Journal-Constitution – Also available on the Huffington Post)

The comment period on proposed changes to the IRB rules has been extended to October 26th. If you have not already done so, please submit your comments!

Under current rules, historians who intend to conduct oral history interviews as part of their research project must first receive approval from the IRB (Institutional Review Board). Researchers are required, among other things, to submit their research proposal, justify their methodology, and provide examples of the documents they will use to recruit, contact, and verify consent of their interviewees. To a certain extent, IRBs insist on standards that are similar to most “best practices” that oral historians follow to ensure that interviewees understand the project and intent of the researcher, how their interview may be accessed and used, and their rights as voluntary participants. Any historian worth his or her salt is committed – on a personal and professional level – to ensuring that the interview process is one of mutual respect, transparency, and careful documentation, from start to finish.

The problem, however, is that IRBs often make unnecessary and unreasonable demands on historians– i.e., insisting that historians complete inappropriate training, have their questions approved in advance, destroy their recordings and transcripts, or obscure the names of the people they interview – because the applications are reviewed against a set of federal regulations known as the Common Rule. In other words, the principles and practices that were established to protect subjects in biomedical and behavioral studies, when applied to social sciences and humanities, create their own set of obstacles. For instance, the process of conducting oral history interviews is one of fluidity and spontaneity. While interviewers may approach an interviewee with a set of questions, rare is the interview that does not include a conversation that goes off on tangent, often a fruitful tangent that sparks a whole new set of inquiries and produces lively and enlightening stories. And rules that were made to protect the identity and well-being of a participant in a medical study can serve to limit the historian in his or her duty to present the historical evidence they find – including the unpleasant pieces.  Certainly, historians must respect their participants’ voluntary consent and make clear how they intend to present or use the interviews. But forcing historians to adhere to the IRBs principles has consequences ranging from time and resources wasted on inappropriate training to thousands of dollars in fines to withheld degrees and suspended research projects.

The good news?

On 26 July 2011, the Office of the Secretary of the 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), opening up the regulations for substantial revision. The ANPRM notes that there are problems with the way IRBs review social science, stating that “Overregulating social and behavioral research in general may serve to distract attention from attempts to identify those social and behavioral research studies that do pose threats to the welfare of subjects and thus do merit significant oversight.” The ANPRM specifically anticipates deregulating oral history:

“Are there certain fields of study whose usual methods of inquiry were not intended to or should not be covered by the Common Rule (such as classics, history, languages, literature, and journalism) because they do not create generalizable knowledge and may be more appropriately covered by ethical codes that differ from the ethical principles embodied in the Common Rule? If so, what are those fields, and how should those methods of inquiry be identified? Should the Common Rule be revised to explicitly state that those activities are not subject to its requirements?”

Robert Townsend of the American Historical Association states that while describing oral history as not creating generalizable knowledge may not be the best justification for reforming these rules, historians must “walk a fine line to represent all members of the discipline, perhaps by reframing the question to address the fundamental problem: the application of completely inappropriate rules and criteria to historical research.”  (See http://blog.historians.org/news/1382/getting-free-of-the-irb-a-call-to-action.)

Historians have an opportunity to weigh in on this debate. You may submit comments in one of two ways to the Department of Health and Human Services until September 22 October 26:

• Federal eRulemaking Portal: http://www.regulations.gov. Enter the docket ID number HHS-OPHS-2011-0005-0146 in the ”Enter Keyword or ID” field and click on ”Search.” On the next Web page, click on ”Submit a Comment” action and follow the instructions.
• Mail/Hand delivery/Courier to: Jerry Menikoff, M.D., J.D., OHRP, 1101 Wootton Parkway, Suite 200, Rockville, MD 20852.

Comments received, including any personal information, will be posted without changes on http://www.regulations.gov/.

For more information, see:

• http://www.hhs.gov/ohrp/index.html
• http://www.hhs.gov/ohrp/humansubjects/anprm2011page.html
• http://chronicle.com/article/Historians-Welcome/128552/

FOR IMMEDIATE RELEASE

Contact: KB Brower, LWC Student Organizer, 610-308-7161

Sit-In at Rutgers

When it comes to budget cuts and policies that hurt students and
campus workers, student activists are refusing to sit down…unless it’s
their President’s office.  In the past week students at 5 major
universities have staged sit-ins for student and worker rights, and
this seems to be only the beginning.

For the past few years students across the country in United Students
Against Sweatshops (USAS) have been running campaigns against budget
cuts and salary freezes that hurt students and already underpaid
workers.  This spring has been blowing up with an impressive show of
student labor solidarity and community activism.  Students in USAS
launched a national “Take Back Our Economy” project and mobilized in
more than 30 cities on March 2 and April 4 to take action in support
of workers’ rights.  A week ago today, USAS activists at two
universities in the Southeast simultaneously occupied their university
president’s offices to demand justice for workers on their campuses.

Student Protestors at Emory Arrested

At Emory University in Atlanta, students staged a 7-hour sit-in after
over 100 students rallied with MLK nephew Isaac Farris Jr. and State
Senator Vincent Fort, to urge President James Wagner to terminate the
school’s multi-million dollar contract with food service giant Sodexo,
exposed for human rights abuses globally. Using Skype, the Emory
activists teleconferenced with USASers at Virginia’s College of
William and Mary, live from their own sit-in in President Taylor
Revely’s office, where students sought resolution to a 10-year
campaign by campus workers for living wages. The William and Mary
group was arrested after midnight, while Emory’s sit-in escalated into
a sprawling “tent city” outside the administration building until
Emory arrested 7 students yesterday. The next day in New Orleans, 21
students at Tulane University took over President Scott Cowen’s
office, singing and chanting to demand that the school kick out Sodexo
and protect campus workers’ rights, leaving 3 hours later after
administrators threatened disciplinary charges and brought in police.

Tuesday, the action came back to Madison, where 70 students occupied
the office of University of Wisconsin Chancellor Biddy Martin to
protest her promotion of a privatization scheme that would lead to
skyrocket tuition and outsourcing good union jobs on campus. And right
now, 20 students continue their occupation overnight of the building
of New Jersey’s Rutgers University President Dick McCormick to stop
tuition hikes, support campus workers, and drop Rutgers’ deal with the
Nike-dominated “Fair Labor” Association.

Students have noticed disturbing trends nationwide since the beginning
of the recent ‘economic crises’ where universities and local
governments implement cuts and policies that hurt working people and
students, while corporations continue to receive record profits and
universities continue to invest in new construction projects and
enormous salaries for university administrators.  It’s time to take a
stand against the corporations that are bankrupting our states and
funding right-wing politicians to attack workers and students.  It’s
time for corporations in Virginia, who have the second lowest income
tax in the U.S, to start paying their fair share in this crisis.  The
Living Wage Campaign is part of a broader movement towards schools,
workplaces, and an economy that works for us.  Although we’re
witnessing enormous state budget cuts to education, William and Mary’s
budget has increased every year for the past 10 years or more.  The
College currently receives less than 13% of our funding from the
state, and relies heavily on private donations and other sources of
funding.  As we more towards a school that looks more private than
public, we need to start considering finding private donors and
sources of money that can go towards living wages, just as we find
these donations for new buildings and projects.  It’s time for our
government and our universities to start prioritizing real people, and
for students to start challenging policies and ideologies that force
our workers to live in poverty and make education increasingly
unaffordable.

To find out more about Living Wages and the history of the campaign,
visit our website wmlivingwagecampaign.com or email
livingwages.wm@gmail.com

Student labor support groups at William & Mary and Emory staged sit-ins in their respective administrative buildings yesterday. I’m not sure what’s happening at Emory but the William & Mary students fighting for a living wage for the college’s lowest paid employees were charged with trespassing last night. It looks like they may also be charged with violating William & Mary’s code of conduct for disrupting the college president’s ability to conduct work.

Please e-mail President Taylor Reveley right now, and call him at (757) 221-1693 to let him know retaliation against students is unacceptable, that he should drop all charges against students immediately, and that even in tough financial times paying decent wages must be the college’s first priority.

Best,

Cindy Hahamovitch
Professor of History
The College of William & Mary