Mission

The mission of the HROB is to ensure that all human remains discovered by any means (intentional or accidental), acquired, used in training or education, or stored by Princeton University employees, including faculty, staff, and students are done so respectfully and in compliance with applicable laws, regulations, and policies. In addition to facilitating legal compliance, HROB recognizes a moral and ethical responsibility to ensure that human remains under the University’s control are managed appropriately. These principles and HROB’s oversight responsibility apply regardless of the location of the human remains, i.e., includes off-campus field research.

Purpose and Scope

The HROB is authorized by The Office of the Provost and memorialized in the Rules & Procedures of the Faculty Rule VIII(C)(5):

“The Human Remains Oversight Board (the HROB) is responsible for providing guidance and oversight for research, educational, and training activities involving human remains, as defined by University policy. The HROB will function in a manner consistent with applicable policies, laws, and regulations, including the Native American Graves Protection and Repatriation Act (NAGPRA). All members of the University community, including students, must obtain approval from the HROB before initiating any University activities involving human remains. The HROB reviews proposals and makes recommendations for the University’s acquisition, usage, storage, display and deaccession of human remains; and maintains a register of human remains in the possession of the University or used under the auspices of the University…”

The HROB operates independently of the Princeton University Institutional Review Board (IRB). 

The HROB is governed by the following regulations and policies.

• Princeton University Use of Human Remains Policy
• Native American Graves Protection and Repatriation Act (NAGPRA) and its regulations
• Princeton University Department of Anthropology “Legacies of Violence and Complicity ~ Current Policies and Guidelines”
• Any other policy or guidance that the HROB and/or Princeton University adopts to foster the implementation of this charter
• Other International Regulations and Policy, as applicable, to specified collection of human remains

Membership

As provided in the Rules, the “HROB is comprised in a manner that provides the breadth of expertise necessary for adequate review of the range of possible activities involving human remains at the University.”  Membership on the HROB shall be comprised of members of the faculty representing relevant departments, which may include Art and Archeology, Anthropology, Religion, representatives from the Princeton University Art Museum, the Library, the Office of the Dean for Research, and the Office of the Provost. Expertise and knowledge about NAGPRA and its implementation will be one of the factors considered for membership. A member from the Office of the General Counsel will serve solely in an advisory capacity. 

In addition to the above members, the HROB may, in its discretion, invite individuals with competence in special areas to assist in the review of issues that require expertise beyond or in addition to that available on HROB. These individuals may be affiliated or unaffiliated with Princeton University and are non-voting guests of the HROB.

Expectations of members

1. Members are appointed by the Dean for Research (IO) for terms of 1-3 years, which may be renewable.
2. New members will receive an orientation and be provided relevant resource materials, including access to all regulations affecting the actions or operations of the HROB, prior to attending their first meeting. Training for members will include, at a minimum, a review of the Charter, the role of the HROB, expectations of HROB members, and on any process involved in the review and approval of proposals. All members are encouraged to participate in continuing educational opportunities to supplement this training.
3. Members are expected to be available to conduct the business before the HROB, and to provide prompt responses to requests from the HROB chair and/or staff. 
4. Members are expected to review all meeting materials in advance of the meeting
5. Members are expected to attend at least 75% of meetings, either in person or via remote access.
6. Members must disclose any real or perceived conflicts of interest (COI) concerning any human remains use proposals before the HROB. Members with COI should recuse themselves from voting on those agenda items. Recusals due to COI will be noted in the meeting minutes.
   1. The recused individual may remain present during the presentation of materials and to answer any questions of the HROB. After that period, the recused should remove themselves to allow discussion and voting to occur in their absence, and thus without their potential to influence.  Any person may request that someone be recused. If there are differences in opinion, the HROB Chair will make the final decision.

Definitions

Human remains: the bodies and parts of bodies of once living homo sapiens. These typically include osteological material (e.g. whole or partial skeletons, individual bones or bone fragments and/or materials that are naturally or culturally shed (e.g. teeth, hair, nails) from deceased human beings.  Human remains may also include any of the above that have been modified in some way by human skill or may be physically bound up with other non-human materials to form an artifact composed of several materials.  

Human Remains do not include art objects, artifacts, representation of human remains (x-ray or CT scans), pictures of excavation sites, sacred objects, and associated funerary objects.

Use of human remains: any use of remains, including the display, handling, storage, photography, analysis, study, or cultural consultation. Note that photography of human remains is limited to photos which are necessary for teaching, research and curatorial purposes, and may be prohibited altogether by the HROB depending on the cultural identity of the remains.

Applicant: the individual who submits an HROB application (Appendix 1). The applicant can include Princeton students, faculty, and staff members.

Responsible Individual: The person HROB will hold ultimately responsible for the appropriate care and use of the human remains, consistent with the HROB’s determination.

Quorum: half of the HROB’s membership, plus one.

Responsibilities

The applicant has the following responsibilities:

1. The individual submits an HROB application to the HROB in advance of acquisition and prior to using any human remains.
2. The individuals listed in the HROB application must be trained on how to respectfully use and manage the remains. This training is led by an HROB designee and is informed by the specific remains’ history and context. 
3. The HROB may recommend that external actors (including affiliated individuals, descendent groups, and communities) be granted permission to handle human remains, to which they have a bona fide connection, without undergoing the training.
4. If the HROB approves the use of the human remains, the individual responsible is responsible for the day-to-day oversight of the human remains as well as compliance with any applicable laws, regulations, and policies as well as determinations of the HROB.

The HROB has the following responsibilities:

1. Issue determinations regarding the use of human remains.
2. Create and maintain a registry of human remains in the possession of the University as well as human remains being used under the auspices of Princeton University, both on campus and in connection with University programs, research, or other activities that occur elsewhere. The registry will reflect the final disposition of all identified human remains, to the extent practicable.
3. Maintain any additional records to demonstrate compliance with applicable laws and regulations. 
4. Report on its activities to the Office of the Provost and the Office of the Dean for Research, at intervals to be determined by the Provost and the Dean for Research. 

Procedures

Confidentiality in the HROB’s proceedings, including the application review process and any appeal, shall be respected throughout, to the maximum extent possible.

This procedure applies to applicants proposing to conduct a project (display, teaching, research, fieldwork, or any other University activity) involving the use, movement or finding of human remains that was not previously approved by HROB.  Applicants must submit an HROB application in advance of any of the above-mentioned activity of the remains. 

Consistent with the Rules and as set forth in Section II. Purpose and Scope of this Charter, the HROB reviews applications and makes determinations that the responsible individual must abide by.  The HROB will meet to review HROB applications, with at least a Quorum of the members present. HROB determinations are made solely at HROB meetings and by a majority vote of HROB members present at the respective meeting. 

In making its determinations, the HROB considers the following information provided in the application in view of the University’s policies, mission, legal obligations, and best practices in the relevant field (if developed and available), which may account for such factors as:

1. the nature of the human remains, including their origin, any cultural affiliation, estimated age, and the identity or existence of lineal descendants;
2. any efforts to engage with the lineal descendants and/or culturally affiliated entities that are the source of the remains and the outcome of such efforts, including with regard to informed consent to acquire and use said remains;
3. how the remains were acquired;
4. how the proposed project is consistent with prevailing ethical standards in the field;
5. any complex histories or events associated with the remains;
6. whether the proposed use will result in damage to or loss of part of the remains;
7. how the proposed storage and security measures will protect and preserve the remains;
8. whether the remains are subject to government regulation, including any local customs/norms or regulations that may be applicable to the acquisition, extraction, transport, import/export, study, or use of the remains;
9. any relevant history regarding regulatory or other governmental clearances or authorizations regarding the acquisition, use, possession or control of the remains, including proof of compliance with such requirements; and
10. the proposed repatriation of the remains, if applicable.

If the human remains under consideration fall within the purview of the NAGPRA regulations, the HROB will review and make recommendations to appropriate University officials to implement, consistent with all applicable legal requirements.

Appeal process: 

Appeals must be made in writing, within 30 days of the HROB determination, and explain the basis for the applicant’s or responsible individual’s challenge to the determination. Appeals may be made by the responsible individual (non-parties may not appeal) to the HROB for consideration. Appeals will be reviewed by a subcommittee of the HROB on a case by case basis. If the outcome is still not satisfactory appeals may be made to the Provost and subject to any applicable and existing University grievance procedures.   The Provost may review the HROB’s determination to assess the fairness of the procedures followed, the appropriateness of the criteria used, and the reasonableness of the decision reached.  The Provost’s decision regarding any proposed use of human remains is final, i.e., supersedes the HROB’s determination. 

Any failure to comply with the HROB’s determinations will be considered by the HROB and forwarded to the Provost for action, as appropriate.

Meetings

The HROB meets quarterly or semi-annually, with ad hoc meetings scheduled as needed. Each meeting must have a quorum of its members in attendance in order to conduct official business as described above.  Meeting discussions are considered confidential.

References

Ethical code of Association of American Museums (AAM)
Ethical code of the Society for American Archaeology (SAA) 
The Norwegian National Research Ethics Committee

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