Who can submit a Non Human Subject Research application?

Answer

A project that does not meet the definition of human subject research is not regulated or overseen by the IRB.  The Non Human Subject Research (NHSR) application (which can be submitted via IRBOnline) is meant to confirm that a project does not meet the definition of human subject research.  If the IRB/OPRS agrees with your decision that the project is not human subject research, you will receive an official NHSR determination.  This means the IRB has no authority over that project.  As such, the project is not subject to IRB policies.  Therefore, the person who submits the NHSR application does not need to meet the PI eligibility criteria for IRB review and an NHSR application can be submitted by anyone affiliated with UIUC.  

The NHSR determination relates to the specific project details, not the individual who submits it.  This also means that CITI training is not required in order to conduct Non Human Subject Research.  

Please note that if you submit an NHSR application and the IRB/OPRS determines that the project may be human subject research and thus requires a new study application, the PI on the new study application must be someone who meets the university's PI eligibility criteria and all research team members must have completed the appropriate CITI training.