Interested Parties Responsibilities
Administration Export Control Responsibilities
University administrators, faculty and staff at all levels share the responsibility of export control compliance in their respective areas. All university employees should be informed on export control compliance issues and share in the responsibility of overseeing, supporting and implementing procedures set forth by the university.
The ORSP provides assistance with identifying export control issues and providing support for a solution.
- reviews the terms and conditions of a sponsored agreement or grant to identify and negotiate out of restrictions on publication and dissemination of the research results;
- has export control checks in the routing form used by principal investigators;
- uses ORSP internal export control checks at routing form and negotiation stage of award lifecycle;
- uploads documentation for each individual sponsored research project or grant into the PeopleSoft system;
- conduct regular training opportunities for the research community;
- uses internal subcontract check list and subcontract risk assessment form to flow through appropriate export control regulations.
Responsibilities Principal Investigators (PI's)
PI’s are the experts in their field including the information and technology utilized in a sponsored research award and is the university representative most aware of the individuals and entities allowed access to the information and technology. They must ensure that controlled information, articles or services are not disclosed to a foreign national unless prior authorization is given. In order to meet their obligations to federal regulations and university policy, each PI:
- is required to participate in regular training opportunities on export control issues and understand their obligations regarding export controls;
- must assist the university is properly classifying information, technology or services involved in the sponsored research activity or grant;
- needs to identify foreign nationals who may be involved with a project, in any way, and if export controls may be involved should initiate the process of obtaining proper authorization in a timely manner or is required to implement appropriate measures to ensure foreign nationals are isolated from participation;
- must brief all participants or isolated individuals of the export controlled project; and
- should work with the designated person to develop a technology control plan.