LEAVE NOT AN INCH OF 
YOUR HIDE UNCOVERED:
HUMAN SUBJECTS
PROTECTION

University policy requires review and approval of all research involving 
human beings. Recent reports from College of Education graduate faculty  
members reveal special zeal by the UniversityÕs Office for Regulatory 
Compliance (OCR) in assuring that graduate students follow this policy. 
Rumor has it that some cases of noncompliance are referred to the Office of 
Conduct Standards (OCS) by ORC.

ORC  and OCS entanglements are serious matters that could delay or stop 
completion of a degree. Taken to its logical administrative conclusion, 
failure to protect human subjects  could also indicate violation of the 
UniversityÕs policy on misconduct in science, which is an offense that 
might be reported to the federal government and could result in the 
destruction of a career. 

You are warned to take special care in complying with University policy on 
use of human research subjects and in maintaining documentation of any 
oral or written advice or decisions the ORC may provide. Especially, you 
should cover your hide with memorandums that summarize oral advice or 
decisions given to you by the ORC. At times, facts disputed during 
investigations of lack of compliance with University human subjects 
policy involve whether discussions with ORC actually occurred as well as 
differences of opinion about the content of advice the ORC provided.

PassmoreÕs official stance is the same as the UniversityÕs: all research on 
human beingsÐÐincluding any  preliminary contacts, pilot studies, or 
subject recruitmentÐÐcannot occur until written ORC approval is received. 
Passmore cannot support you in resolution of any problems you might 
experience with the ORC unless you have wellÐdocumented evidence, which 
will meet common criteria for probative certainty, that you have complied 
with this requirement. Moreover, because of the high stakes that are 
involved, PassmoreÕs personal advice is that you seek legal counsel 
immediately if you believe that the ORC is taking action against you or is 
deciding that you have not met its policy requirements. The ORC does not 
appear to take ignorance of University policy as an excuse for failure to 
meet their regulations, procedures, and practices for protecting human 
research subjects.