Safe & Inclusive Work Environment When Conducting Off-Campus Research

The intent of this requirement is to provide guidance and protection for participants when they do not have ready access to the on-campus in-person resources. If your project participants continue to have such access, no plan is needed. If participants are sufficiently distant from campus such that access to these resources is more limited than they would be if they were on campus, then a plan is needed. Work-from-home by an individual employee would not, for the purpose of this policy, be considered “off-campus” or “off-site.”  “Day trips” or excursions (e.g., to public places, schools, the state fair, a mall) where participants are returning without an overnight stay would not normally require a plan, but a plan should be created if the nature of the off-campus research activity is likely to create a larger-than-normal opportunity for harassment to occur by topic or location (e.g., studies looking at sexual activities, incarcerated individuals, prior knowledge of harassment in the same setting, etc.). If there is any doubt, create a plan. 

Attendance or presentation of research results at a conference does not require a plan; if participants will also engage in the conduct of research activities while attending a conference, a plan would be required. 

This new requirement applies only to research activities. NSF has defined off-campus or off-site research for the purpose of these requirements as “data/information/samples being collected off-campus or off-site, such as fieldwork or research activities on vessels and aircraft.”  PIs are responsible for determining whether the requirement applies to their project or to certain activities on their project. If there happens to be a research component on an award that is characterized as an “other sponsored activity”, then the requirement would apply only to that research component.

If the off-site research is still taking place, send the plan now to the participant(s) right away.  If the off-site research is over, send a copy of the plan promptly to all project participants, copy SRS Compliances Staff (denis.charlesworth@rit.edu), and the RIT Title IX officer (Stacy DeRooy sadcpsa@rit.edu).  (NSF has not specifically identified what corrective actions should be taken, but it may involve an un-affiliated third party at RIT checking with the participant(s) to ascertain whether there were any issues that arose while off-campus that made any participant feel unsafe or needed reporting.)

“Participant” includes all RIT project personnel: employees, students, volunteers, and others working under RIT’s direction (which might include contractors).  For subrecipient personnel, their own institution should have issued a plan for the off-site activity (PIs should verify with the PI of the subrecipient organization that this has occurred.)  Typically, a RIT PI will only assume responsibility for RIT participants but there may be cases where guests or participants from other entities may need to use RIT’s plan, please talk to SRS if this situation arises.

Yes, in fact it is advisable to have a primary and a secondary point of contact available. The Principal Investigator must be listed on the form in the “PI” box but may also be listed as the primary point of contact, or they may delegate the primary point of contact responsibility to another individual who is present at the off-campus location. Make sure and include the cell phone and email of the alternative contact. 

As described above, it is helpful to list contact information for two individuals (e.g., the PI and a second delegated person such as PI) so that there is a local second-point-of-contact readily available. Assuming there is internet or cell phone service, the participant can also use one of the other reporting mechanisms to contact their supervisor or a University official responsible for handling misconduct concerns. If the participant is unable or unwilling to notify the primary point of contact and the standard reporting options are not available, the participant may defer reporting until access is available (if they feel it is safe to do so), or approach another senior person on the off-campus team (whether or not from RIT) to assist them in appropriate next step.

PIs may devise options they believe are appropriate to the circumstances in the plan, but some reasonable options to certain known circumstances might include the following: 

1. Cultural norms differ in the location where the off-campus research will take place. PIs may wish to offer a “pre-departure” briefing for participants explaining cultural norms in the off-site location (physical or touching norms, verbal styles, etc.) PIs can offer alternatives to mitigate concerns arising from cultural differences (e.g., offering to connect only in a group setting, or pairing participants so that there is less opportunity for misunderstanding.) 
2. In advance of departure, PIs may wish to remind participants that they are personally available to listen to any concerns that participants may have about the off-campus research. 
3. If the off-campus research site offers terrain, temperature, visual, auditory, or other challenges, offer to meet ahead of time with participants to discuss any special concerns they may have or accommodations they may need in order to fully participate. 
4. The PI may wish to engage in regular “check-ins” with off-campus participants to ascertain whether there is anything that is impacting their full enjoyment about the off-campus research experience (physical or cultural barriers, behavior challenges, etc.) . 
5. Particularly in remote locations, physical circumstances may limit the ability for a participant to be separated from an individual alleged to have participated in misbehavior.  Whenever possible, the participant and the individual allegedly engaging in misbehavior should be separated as completely as possible. With the participant’s concurrence, consider assigning a “buddy” to help that participant feel safe as well as reduce the likelihood of a possible recurrence - particularly when complete physical separation is not feasible. 
6. There is only a single satellite phone (or internet equivalent) available for contact outside the group. Consider having a second phone available and controlled by a different individual or ask someone from another group or from the entity being visited if participants can also approach them should need arise for a confidential call to be placed. Consider budgeting for a second phone if that is what is needed to ensure alternate access can be available. Notify participants of their options accordingly.

Use the plan document to describe as best you can the nature of the planned off-campus research activities. The plan may be updated at time of award or prior to the off-campus research activity being undertaken. The plan MUST be updated (if updates are needed) and distributed prior to the off-campus activity taking place, but no approvals are needed to make changes. For audit purposes, make sure you or your departmental office retain a copy of the plan that was distributed to participants.

As of February 2023, the two NSF directorates that have indicated a need for alternative plans in some of their solicitations are BIO and GEO. PIs should carefully review their NSF solicitations to ascertain whether an alternative format is required for their plan. In general, the alternate plan requires a two page supplemental document to be submitted with the proposal that includes specifics in 4 areas – see the link below for details. In the event an NSF directorate requires an alternative arrangement, follow NSF’s instructions rather than the general ones provided here – it is NOT necessary to complete the University’s template. 

NSF held a Virtual Office Hour on this topic and although that event is over and does not appear to have been recorded, the NSF website still contains valuable information about these requirements and initial NSF solicitations where these alternative arrangements exist.

No. SRS will be unable to offer extensions, as the SR signatory for the proposal must sign a certification saying that we are following the requirement to have a plan at time of proposal submission. Before that time, SRS will work with PIs to address unusual circumstances, recognizing that individuals are still learning about the requirement.