Compliance FAQ

Q: I am in interested in a request for proposal (RFP) that says the project may be subject to export controls (ITAR, EAR, OFAC, NRC, etc). What do I need to know?

A: Please check out the UMOR Export Control site, the export control manual and/or contact Elizabeth Wagner (elwa@umich.edu) to discuss the restrictions that may apply to the project.

 

Q: I am submitting a proposal for a project that might have ‘export controls’. Does this get noted on the eResearch Proposal Approval Form (PAF)?

A: You should answer ‘yes’ or ‘unsure’ to Question 5.9 on the PAF: “Does the research project involve classified research or possible export controls?”  At the time of award, you will be asked for more details, and the Export Control office will work with you to determine if you need a Technology Control Plan, an Export License, or both.

 

Q: What are export controls?

A: http://research-compliance.umich.edu/export-controls

 

Q: What is ITAR? What is EAR? What is the difference between them?

  1. International Traffic in Arms Regulations (ITAR)(link is external) from the U.S. Department of State (Directorate of Defense Trade Controls) which covers items and services related to military/defense applications, including spacecraft and satellites.
  2. Export Administration Regulations (EAR)(link is external) from the U.S. Department of Commerce (Bureau of Industry and Security) which covers “dual use” civilian/military items and technology.

Q: Where can I get export controls training?

A: http://research-compliance.umich.edu/export-controls-training

 

Q: Where can I learn more about export controls? 

A: http://research-compliance.umich.edu/files/u-mexportcontrolcompliancemanualdocx and the UM Export Controls website.

 

Q: What is a PAF-R?

A: Your ORSP project representative will work to negotiate out restrictive clauses from your research agreement or contract. If there are restrictions on publication or the dissemination of research results, you will need a PAF-R (Proposal Approval Form-Restricted). This is a supplementary Proposal Approval form for review of restrictions on publication or dissemination of research results.

  1. ORSP, Attachment 1: Description of the non-standard or classified restriction on openness and the negotiations to remove it.
  2. PI, Attachment 2: Description of the research.  Identification of implications of the restriction for education of students, scholarly exchange, and management of personnel and facilities and justification for accepting the restrictions.
  3. Department Chair, Attachment 3: Description of the impact of the restriction on the Department, its faculty, graduate students, and others and the Department’s rationale for supporting the request.
  4. Associate Dean for Research. Attachment 4: Description of the impact of the restriction on the School, its faculty, graduate students, and others and the School’s rationale for supporting the request.

Q: How do I route a PAF-R?

A: A PAF-R must be routed for signature outside of the eResearch system. There is a cover page and 4 attachments. The ORSP project rep will provide attachment 1 which describes the project restrictions. The PI should complete attachment 2 or 2B. Each statement/attachment is builds on the other so they should be routed sequentially by email.

 

Q: What is a technology control plan (TCP)?

A: See here.

 

Q: Who is the UM export controls officer?

A: Krista Campeau  (exportcontrols@umich.edu or 734-615-0672)

 

Q: Is there someone at the college who can help me with export controls?

A: You can contact Elizabeth Wagner (elwa@umich.edu). Elizabeth’s role is to triage and support faculty members with research projects that have compliance requirements.

 

Q: What IT resources are there for restricted research at UM?

A: UM sensitive data guide http://safecomputing.umich.edu/dataguide/?q=node/59

 

Q: Can I send export controlled information via email?

A: You should not use your M+Google email to send export controlled data. Faculty, students and staff on export controlled projects or projects with other sensitive data restrictions can use the UM ITS Exchange Outlook email. To request an ITS Exchange account, contact Elizabeth Wagner and your department IT lead.