There is much within the question that is hypothetical. This makes it difficult to answer without fully understanding the conditions that would govern such a submission and examination. One such condition that is very significant is whether the review would be conducted by a not- for- profit organization or whether it would be undertaken with corporate support. Increasingly, it is becoming evident that IRB's are becoming extensions of corporations, and domains where "for-profit organizations are increasingly [being] hired to conduct ethics reviews." It is not out of the realm of possibility that television networks would do their part to influence the outcome of such a review. Certainly, this would impact whether Reality Television would be seen as something that impacts the well- being of its participants.
I think that a case can be made that there are ethical challenges in many Reality Television contexts. The emotional dynamics that are rendered on Reality Television is "real." It is presented as real. These situations can blur the line between what is contrived and what is understood as reality. This can be endangering to the psychological well- being of subjects. It might be in this domain where an IRB could conclude that Reality Television constructs a distinct reality for harm of those involved and viewing it. If "Reality TV is about setting up real danger," then this is a condition that would not ensure the psychological well- being of those who are involved with it.