Is IRB review required for survey results that may be published?

Question: Is IRB review required for survey results that may be published?

I am working with a for-profit company to develop survey questions for patients who have a specific illness. Without IRB approval I may not be able to publish any results; but, getting IRB approval or a document showing exemption is too clunky and time consuming for this kind of work. Is it ok to simply wait to see if anything publishable comes of use of the survey instrument and then get retrospective approval?  I just don’t have time to submit an application to IRB for an activity that is only sometimes going to lead to publication.
– Professor at a medical school

Response:

Institutional Review Board (IRB) oversight requirements depend on if a survey meets the regulatory definition for human subjects research, rather than future publication plans. Investigators must consult their local committee to discover whether specific projects need formal approval or qualify as exempt. IRBs may not grant retrospective approval to research that has already been completed.