Comment by ineedasername

Agreed: sending an email is certainly manipulating their environment when the action taken (or not taken) as a result has the potential for harm. Imagine an extreme example of an email death-threat: That is an undeniable harm, meaning email has such potential, so the IRB should have conducted a more thorough review.

Besides, all we have to do is look at the outcome: Outrage on the part of the organization targeted, and a ban by that organization that will limit the researcher's institution from conducting certain types of research.

If this human-level harm was the actual outcome means the experiment was a de fact experiment including human subjects.