> Please don't use such circular logic. We're debating whether the research properly qualifies as human subject research; we're not debating about what the IRB actually decided on that question, because they may have gotten it wrong.

Yes that's what we're debating. But you used the word "exemption" which has a specific technical meaning in human subjects research, and I'm saying that it's not an exemption. There are 8 tests for exemption, and I'm pointing out that this is not an IRB exemption.

> The policy itself is certainly the intended subject of the research. But the methods they've chosen mean they are also collecting and analyzing information about the responses of real live humans to their interactions and interventions, and that qualifies this as human subject research irrespective of the naive intentions of the researchers. Having a non-human subject does not preclude also having a human subject.

Do you have a source for this interpretation? It sounds like this is your interpretation, but not the federal one. Following your interpretation, surveys of companies (e.g. emailing contact@company.com to ask how many employees they have) would fall under the definition of human subjects.

Thanks for the continued conversation, but I think this is my last comment. Nothing personal, but this is a bit exhausting. It seems like you're debating two other people on this forum about this exact definition, and you might consider that maybe you're just wrong about your interpretation?

Here's one final source, if it helps provide closure:

To meet the definition of human subjects, you must ask “about whom” questions. Questions about your respondents' attitudes, opinions, preferences, behavior, experiences, or characteristics, are all considered “about whom” questions. Questions about an organization, a policy, or a process are “about what” questions.

https://campusirb.duke.edu/resources/guides/defining-researc...