RANDAZZO 005 - The AAA "Do No Harm" Mandate vs. the IRB Classroom Carveout: How Non-Standardized Consent in Pedagogical Assignments Breaches Professional Ethics and Amplifies Liability

This article argues that the common reliance on the IRB “classroom activities” carveout to excuse consent formalities in student interview assignments stands in direct tension with the American Anthropological Association (AAA) Code of Ethics—especially its first principle to “do no harm.” By design, the carveout permits human‑subjects interactions to proceed without standardized consent instruments and without institutionally‑vetted disclosures about third‑party processing and retention. As demonstrated in Randazzo 001–002, the result is a structural consent vacuum that (i) elevates §632 exposure when recordings are made and uploaded to vendor platforms; and (ii) invites coercion via grading, triggering Bane‑Act risk. Independently of legal exposure, these pedagogical designs contradict AAA’s core ethical mandate and may amount to professional misconduct by university officials who assign, approve, or administer such coursework without safeguards. We formalize the contradiction, analyze the ethics‑to‑governance gap, and propose a remediation architecture aligned with AAA’s standards.