[billjive]

That is right, and further - I think about IRBs like I do non-profit boards. One of the key tasks of a board is to determine what risk the organization is willing to bear. I think the IRBs at these institutions are 1) following federal laws but 2) making a judgement on the risk the institution is willing to sign up for. For example, for many clinical trials are distributed to multiple "sites" where the trial is actually administered. Many of these sites are universities. What the University of Iowa is willing to bear is different than the University of Michigan and the IRBs reflect that.