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 Rick Vanden Heuvel (hoovervh@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: If you think you may have an export control concern on a proposal, you should answer ‘yes’ or ‘unsure’ to Question 5.9 on the PAF: “Does the research project involve classified research or possible export controls?”  The PAF will then be flagged in eReseach and allow the Export Control team the opportunity to contact you and discuss the next steps.   In most cases, ORSP and the export control team will ask for more details at the time of award unless otherwise needed.   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/sites/default/files/u-m_export_control_program_manual.pdf 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 approval of restrictions on publication or dissemination of research results.

  1. ORSP will create an Agreement Acceptance Request form in the Unfunded Agreements section of eRPM. It will be linked to your PAF.
  2. The PI or research administrator should upload a brief description of the research and explain how the restriction will affect the education of students and scholarly exchange, and describe how impacts on student academic and research progress will be addressed and managed, and provide his/her rationale for accepting the restrictions. This will route the PAF-R to the department chair.
  3. Department Chair: Approves with an uploaded description (memo) 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: Approves with a 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.
  5. Vice President for Research: Final Approval

Contact Linda Forsyth (lforsyth@umich.edu) with any questions or for more information.

Q: How do I route a PAF-R?

A: A PAF-R is routed as an Agreement Acceptance Request in the eRPM system.  The ORSP project rep will provide information on the nature of the restriction, and the contract/grant clause that requires it, and the AAR will be electronically routed for PI, department, CoE, and UMOR approval.

 

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

A: click here.

 

Q: Who is the U-M 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 Rick Vanden Heuvel (hoovervh@umich.edu). Rick’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: Do not use your M+Google email to send export controlled data as it is not a secure method of transmission.  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 your department IT lead.