Policy on redacting IBC meeting minutes and/or protocols prior to release

Revised Approved – August 8, 2018
Original Approved by the IBC on December 10, 2008

IV-B-2-a-(7) of the NIH Guidelines states: “Upon request, the institution shall make available to the public all Institutional Biosafety Committee meeting minutes and any documents submitted to or received from funding agencies which the latter are required to make available to the public.”

Where “any documents submitted to or received from…” includes, as exemplified from Section IV-B-2-a- (3) of the NIH Guidelines, “IBC’s must submit committee rosters and biographical sketches of members to the NIH Office of Science Policy (OSP).” Thus, under the NIH Guidelines IBCs are required to make rosters and biographical sketches that have been submitted to NIH available to the public upon request.

If public comments are made on Institutional Biosafety Committee actions, the institution shall forward both the public comments and the Institutional Biosafety Committee’s response to the National Institutes of Health: Office of Science Policy, preferably by e-mail to: [email protected]. Additional contact information; 6705 Rockledge Drive, Suite 750, MSC 7985, Bethesda, MD 20892-7985 (20817 for non-USPS mail), (301) 496-9838, (301) 496-9839 (fax). CSU may redact certain information from these documents if there are privacy or proprietary concerns.

SOP ON REDACTING IBC MEETING MINUTES OR PROTOCOLS PRIOR TO RELEASE

The items listed below will be redacted if the IBC is requested to release meeting minutes and/or protocols:

  1. All locations
  2. Names of researcher staff, other than the Principal Investigator, including Research Associates, graduate students, etc
  3. Any private information, such as eID names, personal telephone numbers, etc
  4. Proprietary/potentially patentable information

If IBC PARFs or AARFs are requested, PIs will first be permitted to redact proprietary information, and then the items listed above will be redaction. The Office of General Counsel (OGC) will then provide legal review of the redactions, and as per CSU policy, OGC will make the final determination on the release of any material.