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Open Access Publications from the University of California

UC Comments on FDA Docket No. FDA-2019-N-2175 for “Institutional Review Boards; Cooperative Research.” (September 28, 2022)

Abstract

This comment letter responds to the FDA’s proposed rule requiring single Institutional Review Board (IRB) review for cooperative research and harmonizing FDA requirements with the Common Rule. UC supports greater regulatory alignment but recommends updated analysis of the costs and administrative burden of single-IRB review, clearer exceptions for certain studies and circumstances, greater discretion for local IRBs, and streamlined reliance agreements.