Citizen Scientists, IRB Challenges, and Regulatory Gaps

February 19th, 2025

Whether citizen science projects require internal review board (IRB) oversight depends on their classification under the Common Rule for human subjects research. Althoughmany citizen science projects are exempt, some conducted in collaboration with universities or nonprofits may still fall under IRB jurisdiction.

Key IRB Challenges

• Defining "human subjects":
  • A photo of a bird uploaded by a citizen scientist is not human subject research.
  • However, if location data are attached (e.g., taken at home), they could fall under privacy concerns covered by the Common Rule.
• Participant compensation ethics:
  • Traditional IRBs use an "equal pay for equal work" model, but in citizen science, an equity-based compensation model may be more ethical.
• Autonomy vs. engagement:
  • IRBs typically protect autonomy, but citizen science focuses on active engagement, making traditional IRB concerns (e.g., privacy risks) sometimes less relevant.
  • Conversely, IRBs may overlook ethical issues like power imbalances and participant exploitation — critical concerns in citizen science.

IRBs must evolve to account for the different ethical priorities in citizen science, rather than solely focusing on regulatory compliance.

Future Considerations for IRBs

• Improve understanding of citizen science to ensure ethical oversight aligns with real-world concerns.
• Address power imbalances and ensure fair treatment of participants in citizen science research.
• Expand regulatory frameworks to include ethical considerations beyond traditional human subjects research.
• Encourage transparency in data sharing and research findings to maintain trust in citizen science.

Conclusion

Citizen science is not a passing trend — it is a growing movement in research. However, ethical oversight remains inconsistent, and IRBs must adapt to address new challenges in participant engagement, data ethics, and power structures. The regulatory landscape must evolve to support both innovation and ethical responsibility in citizen science projects.

For a deeper look at the challenges and considerations for citizen science projects, click here.