Based on OHRP’s guidance on who is “engaged” in human subjects research as members of a research team, an interpreter would not be considered a member of the research team in cases where they perform commercial or other services for researchers provided that these conditions are met:
- the services performed do not merit professional recognition or publication privileges (not named as authors or co-authors of a study);
- the services performed are typically performed by the interpreters for non-research purposes (organization or business provides language interpretation outside the research context);
- the interpreters are not the primary person who will administer any study interventions/questionnaires/interviews being tested or evaluated under the protocol;
- the interpreters are not the primary person obtaining informed consent of human subjects for the research.
Persons who will perform any of the above must be named a member of the research team in an IRB application and is required to take IRB-required CITI training.