“…As IRBs navigated their responsibilities to participants, researchers, and federal oversight bodies, both IRBs and the Common Rule were widely critiqued as overtly positivistic and paternalistic (e.g., Gunsalus et al, 2007; Schneider, 2015; Schrag, 2010; Tuck & Guishard, 2013). The revised Common Rule addresses many of these concerns in nuanced ways (see, e.g., Phelps, 2020b). But the current policy retains many characteristics of the original Common Rule, including the opportunity for wide interpretation and application by street-level bureaucrats (SLBs; Lipsky, 2010).…”