ORS Policies and Forms

Summary of ORS Procedures involving Export Controls in Sponsored Research Proposals:

1. When completing a sponsored research proposal, Principal Investigators should seek to determine if the technologies covered by the research proposal are covered by Export Controls and indicate such on the ORS Proposal Transmittal and Approval form. This website contains guidance on making that determination and ORS staff should be contacted to assist in making the determination. As the individual most knowledgeable about the technologies that will be covered by a sponsored research proposal and the administrator of the technical aspects of the research, the PI is largely responsible for ensuring compliance with the requirements of the Export Control Laws in their research program at the University of Pennsylvania.

2. When a sponsored research proposal is received in ORS, the Contract Administrator will review it and, if necessary complete the ORS Export Control Review Form. Upon completion of the form, the Contract Administrator will determine with the PI if the sponsored research proposal is or is not subject to Export Controls. For example, if the sponsored research proposal falls into the Fundamental Research Exception, then it is not subject to Export Controls. Alternatively, negotiation of the grant or contract may result in the removal of terms and conditions that otherwise would have subjected the sponsored research proposal to Export Controls. If not subject to Export Controls, the sponsored research proposal will be handled as usual. If subject to Export Controls, ORS, in consultation with the Office of General Counsel, shall take further necessary action. This may involve an application for the appropriate license, further review by outside counsel, or a determination that the sponsored research proposal should be modified or abandoned. Final decisions on the status and handling of sponsored research proposals subject to Export Controls shall rest with the VP Research.

ORS Export Control Review Form
Form to be completed by ORS Contract Administrator in review of Research Proposals.