Comment by bonniemuffin

I'm surprised that the IRB determined this to be not human subjects research.

When I fill out the NIH's "is this human research" tool with my understanding of what the study did, it tells me it IS human subjects research, and is not exempt. There was an interaction with humans for the collection of data (observation of behavior), and the subjects haven't prospectively agreed to the intervention, and none of the other very narrow exceptions apply.

https://grants.nih.gov/policy/humansubjects/hs-decision.htm