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Open Access Publications from the University of California

UC Comments on Docket No. FDA-2021-N-0286 for “Protection of Human Subjects and Institutional Review Boards” (September 28, 2022)

Abstract

This comment letter responds to the FDA’s proposed rule revising human-subject protection and Institutional Review Board regulations to better align them with the Common Rule. UC supports harmonization but recommends closer alignment on definitions, informed consent, activities preparatory to research, waivers of consent documentation, and continuing IRB review, as well as a longer implementation period for the final rule.