Review by an EDO is required for activities that are or might include HSR, when conducted by a DAF investigator. Because an investigator cannot make determinations about their own activities, and EDO will make a formal determination as to whether the activity is or is not Research, includes the use of Human Subjects, and if the activity is HSR, whether the study meets any of the eight Exemption categories found at 32CFR219.104(d).
Unless the activity is non-Exempt HSR, a determination from the EDO is often sufficient to allow the activity to commence, once all other approvals have been secured.