Research Compliance

Our office is here to assist you in these tasks in any way that we can. We suggest that you contact us early in the proposal preparation process, so that we may guide you in the approvals and submission process.

This webpage references policies governing sponsored projects at RIT. All project investigators and personnel are required to comply with these policies as well as applicable federal and state regulations.

• Externally Sponsored Projects Disclosure Policy
• Compliance with the National Science Foundation’s Responsible and Ethical Conduct of Research (RCR) Requirement
• Human Subjects Research & Institutional Review Board (IRB)
• Export Control
• Individual Conflict of Interest and Commitment Policy
• Intellectual Property Policy (administered by the Intellectual Property Management Office)
• Policy Prohibiting Discrimination and Harassment
• Misconduct in Research and Scholarship (responsible official is the Vice President for Research)
• Information Security Policy

All members of the RIT community, including faculty, students, and staff, are expected to adhere to the highest ethical and professional standards when pursuing sponsored project activities. Involvement with externally sponsored projects elevates these expectations to obligations because sponsors impose significant statutory and regulatory administrative requirements in connection with funding provided for these projects. This policy explains RIT's commitment to the legal and ethical administration of externally sponsored projects; provides administrative guidance to ensure compliance with the necessarily dynamic policies associated with such projects, and enables the Principal Investigators (PIs) and their operational units, Sponsored Research Services (SRS), and Sponsored Program Accounting (SPA) to facilitate the orderly administration of such externally sponsored projects.

View the Administrative Policy and Procedures for Externally Sponsored Projects

Multiple federal agencies have regulations requiring universities to have a financial conflict of interest disclosure process. The Public Health Service (PHS), which includes the National Institutes of Health (NIH) and seven other funded agencies have more rigorous financial conflict of interest procedures for their awards.

RIT meets these requirements through its Conflict of Interest Policy, its annual Conflict of Interest Disclosure process in Novelution, and its questions during the proposal submission process. All PHS researchers must identify themselves in the RIT Conflict of Interest module (Novelution) to ensure they are asked, and complete, all applicable questions as required by PHS. After RIT’s review of any disclosed conflict of interest, if necessary, a plan to manage or eliminate the conflict is developed. RIT will comply with the PHS regulations and notify the PHS funding agency if a significant financial interest exists, and if it is related to the project.

Annual FCOI Disclosure, and at time of application

As part of the annual RIT conflict disclosure process, all faculty and staff will now be asked if they have applied, or intend to apply, for PHS research funds in the coming year.  If yes, those affected individuals will be asked additional disclosure questions. This annual disclosure will be reviewed as part of the RIT Conflict of Interest Policy and Procedures. Investigators will still be asked on the RIT proposal process during the time of application for PHS funded research to certify if any financial conflict of interest exists in each proposed project.

PHS FCOI Procedures

PHS regulations require any individual designing, conducting, or reporting on the research to complete FCOI training and to provide additional financial disclosures. RIT defines such individuals as the PI and Co-PIs on the project pursuant to the RIT Administrative Policy and Procedures for Externally Sponsored Projects. For NIH funded projects, this will include PI/Co-PI, and Senior/Key Personnel. RIT recognizes that other individuals working on a project may have such responsibilities in a particular project as determined by the PI. In such cases, it is the responsibility of the PI to provide the names of those individuals to SRS in writing. SRS shall then require those individuals to complete FCOI training and the additional financial disclosures requested in the RIT Novelution system. 

Disclosure review upon receipt of Award

After notice of receipt of a PHS funded award, OVPR Compliance staff will review the disclosures of the PI/Co-PIs for possible FCOI.  Determinations of Significant Financial Interest (SFI) and Relatedness will be made by the OVPR’s research Compliance staff.  Any disagreement by a PI/Co-PI or key personnel with regard to the decision regarding whether a project is “related” to a SFI under the regulations will be resolved by the Vice President for Research (VPR).  The VPR is the RIT Institutional Official for PHS funded research  The VPR may solicit information and opinion on any of these issues from faculty and staff appointees to a PHS FCOI Review Committee chaired by the Vice President for Research.  PHS Project researchers may be asked to submit additional information for RIT to make its relatedness determination.  The final decision of the VPR will communicated to the affected employee(s) in writing.  OVPR Compliance staff will assist in creating the applicable RIT Conflict Management Plan and if necessary, any Project Specific Addendum(s) to the plan.   

Reporting

OVPR Compliance staff will submit all required filings with the sponsor, coordinate all required annual, compliance, and situation specific PHS related FCOI reports to the PHS funded agency, including any retrospective reviews reviewed required for non-timely disclosures or noncompliance by an investigator. 

Subrecipient Compliance

The Office of Sponsored Research Services (SRS) will ensure subrecipient compliance with all PHS FCOI procedures prior to any subawardee obtaining PHS funds through RIT. Prior to funds expended to a subrecipient, SRS will obtain a written agreement indicating that the RIT subrecipient will follow and submit to RIT’s PHS funding procedures herein for FCOI review on the project, or a certification that the subawardee will follow their own procedures, and their FCOI procedures comply with the PHS regulations. 

Required Training

PHS regulations require that each investigator (including co-PIs) complete FCOI training at least every four years, and/or prior to engaging in PHS funded research, or immediately for new investigators or noncompliance situations.  RIT provides this required training through the Collaborative Institutional Training Initiative (CITI) training FCOI module. This required PHS FCOI training will be required by all named project key personnel prior to issuance of a PHS funded account, in addition to any RIT required training as part of the RIT Conflict of Interest Policy. 

Public Access

RIT’s Conflict of Interest Policy and these Procedures will be publicly available on RIT websites. Any determination by  RIT that a SFI exists that is related to a PHS funded research project shall have the minimum regulatory required data elements of that FCOI available to the public within five days of a written request for that information having been received by the Vice President for Research.

The Human Subjects Research Office (HSRO) and the Institutional Review Board (IRB) at RIT exist to protect the rights, safety, and welfare of the people who take part in research.   

All sponsored research projects at RIT that involve human subjects research will be required to be reviewed and approved by the HSRO in a comprehensive submission to that office, before any human subjects research can commence.  Detailed information and procedures are available on these issues, including when research needs to be reviewed and how to initiate the process are located at the HSRO website.

Protection Statement

The following is a statement that PIs can include in their grant if they are asked about human subjects protections at RIT: 

"RIT subscribes to the basic ethical principles underlying the conduct of research involving human subjects as set forth in the "Belmont Report." RIT's Federal-Wide Assurance assures compliance with the Common Rule in the Code of Federal Regulations (45 CFR 46) for the Protection of Human Subjects. The RIT Institutional Review Board (IRB) and the Human Subjects Research Office (HSRO) are charged with ensuring the protection of human subjects in research. They have the responsibility and authority to review, approve, disapprove, or require changes in research activities involving human subjects. All research activities involving human subjects must be submitted to the HSRO for review before any interaction with participants. This policy applies to all research studies conducted at RIT, regardless of whether the project is funded externally, internally, or receives no funding support."

RIT cannot perform any biosafety work beyond biosafety Level 2 (BSL2) on its campus.

Biosafety is the discipline addressing the safe handling and containment of infectious microorganisms and hazardous biological materials. There are four biosafety level (BSL) risk groups– BSL1, BSL2, BSL3, and BSL4. The higher the level, the more risk associated with that biological agent. Therefore, each level has specific containment guidelines to ensure those working with the biological hazard are kept safe.  All PIs will be asked if their project involves biological or RDNA materials in the proposal submission process.  If positive, the PI will have to work with the EH&S department to meet RIT safety protocols before work can begin. 

In addition to its Environmental Health & Safety (EH&S) department, RIT has an Institutional Biosafety Committee (IBC) to oversee all biohazards and infectious agent projects regardless of the source of funding and/or if they are conducted on campus, or sponsored by RIT. This committee is comprised of individuals from applicable academic disciplines on campus as well as required non-RIT individuals with appropriate expertise. This committee ensures the implementation of policies and manages potential hazards related to biological materials at RIT by reviewing specific project protocols and procedures. 

All sponsored research projects at RIT that involve biological materials will be required to be reviewed and approved by the IBC in a comprehensive submission to that office before any biological research can commence.  Detailed information and procedures are available on these issues at the IBC website located here:  Biosafety | Environmental Health & Safety | RIT.

Any proposal involving the use of chemical materials or hazardous waste must be noted by the PI in the RIT proposal submission process.  PIs will be expected to answer these screening questions accurately on the RIT proposal submission.  All projects will then be reviewed and approved for safety compliance issues by time of award in coordination with RIT’s Environmental Health & Safety Office.  (Environmental Health & Safety | RIT ).    

The following summary information is provided for PIs by EHS.  Please contact them via their website for more detailed information and for required training. 

Hazardous Waste:

If a project will generate hazardous waste, the PI must evaluate how much will be generated, the cost of disposal, any unknown waste that may be generated, and how they will manage the waste in accordance with EPA and NYS Dept. of Environmental Conservation rules and regulations. It is required that the generator make meaningful attempts to minimize the hazardous waste produced. EHS is responsible to oversee the waste disposal at RIT and will need specific information and proper labeling on each waste product. RIT is considered a "large quantity generator" (LQG) under the regulations which requires additional storage, labeling and handling procedures.

Chemical Safety:

A critically important component of any lab safety program is the evaluation of the hazards in the lab and the protection of the employees and students working in the lab. Extremely toxic materials (P-listed chemicals) need to be scrutinized carefully as to how they are used (in a lab hood) and if there is a substitute that is less toxic. Minimizing the use of highly toxic materials by micro-scaling experiments is very effective in reducing exposure and minimizing the waste generated.  Within each College at RIT only certain individuals are approved for hazardous materials and chemical procurement.  Please contact EH&S to determine the correct process that will be needed for your project.  RIT is also legally required to maintain an inventory of chemicals used on campus, and uses MSDSOnline software for this purpose.  All PIs and lab directors/managers will be required to be report chemicals used in this system. 

Laser Safety 

Light Amplification by Stimulated Emission of Radiation (LASER), which produces an intense and highly directional beam of light, are used in many teaching and research applications on RIT's campus. The human body is vulnerable to the output of certain lasers, and under certain circumstances, exposure can result in damage to the eye and skin. Therefore, special safety precautions must be taken and personal protective equipment used when lasers are in use.  Whenever laser are to be used in a sponsored project the PI should ensure that all required inspections of the Laser have occurred, safety training of research personnel was completed, and RIT’s Laser Safety Plan is followed. 

Radiation Safety 

PIs should know that RIT has a designated  Radiation Safety Officer who , must approve the purchase order of any radiation generating material prior to it being issued by RIT. RIT’s NYS license and registration to handle these materials must be updated prior to custody on campus. This is a requirement of the NYS Dept. of Health and RIT's written Radiation Safety Program. PIs should contact EH&S Radiation Safety Office for a review prior to any sponsored project use of these materials so that proper training and approvals pursuant to NYS regulations can take place.   Finally, PIs should be aware that If radioactive waste is going to be generated on a project, the cost  for disposal is prohibitive and the administrative  work involved is substantial.    

All proposed research with vertebrate animals (all fish, amphibians, reptiles, birds and mammals – except human) requires RIT Institute Animal Care and Use Committee (IACUC advance notification and approval.  PIs should contact l SRS and they will be directed to the IACUC chair  for a proposal template that must be completed, submitted, and approved prior to any vertebrate animal research occuring.  

Currently there are no AALAC Assured animal care facilities on RIT’s campus. Federally funded (NSF and NIH) research involving vertebrate animals requires an NIH Animal Welfare Assurance that RIT currently does not possess. Consequently, PIs are strongly encouraged to contact their funding agency program officers and ask whether the proposed research with vertebrate animals requires documentation including an Institutional NIH Assurance of Compliance.  

RIT IACUC (Institute Animal Care and Use Committee) advance notification and approval is sufficient for certain non-federally funded research with some species of vertebrate animals (all fish, amphibians, reptiles, birds and mammals – except human).   

Research with invertebrate animals (all but fish, amphibians, reptiles, birds and mammals) requires no IACUC (Institute Animal Care and Use Committee) notification or approval.  

Research with microorganisms (bacteria, protozoans, etc.) is sometimes permissible (depending on pathogenicity of proposed species) and does not require IACUC approval, but may require approval from the RIT Biosafety Committee. Specialized equipment is usually required for containment and culturing these species so the PI and department hosting the research are responsible for procuring the necessary equipment (incubators, autoclaves, etc.). Please see the Biosafety website for specific information. 

What if I need to work with vertebrate animals for a sponsored research project? 

PIs who need to work with vertebrate animals and a facility that has an Animal Welfare Assurance or a facility that is AALAC approved, should seek these facilities and services from a subawardee or project collaborator, as RIT does not have such approvals and facilities on its campus.  

Can I work with mice? 

Permission for the use of mice as model organisms depends on regulations of the agency sponsoring and funding the research. NIH and NSF require documentation of an Institutional NIH Assurance of Compliance (not available at RIT) in addition to IACUC approval (available at RIT). Other agencies may or may not require an NIH Assurance of Compliance. The PI and departmental unit proposing to host the research are strongly encouraged to contact sponsoring agencies and inquire about regulations regarding use of mice in research. 

Can I anesthetize animals for research? 

Research proposals that require the use of anesthetics or involve euthanizing animals require IACUC approval prior to any work proceeding. These techniques must comply with the latest AVMA guidelines regarding anesthesia and euthanasia. 

However, there is currently no New York State or Federal DEA permit to RIT for the use of controlled substances (for anesthesia or any purpose) on the RIT campus. It is possible for RIT to decide to apply for such permits, but there are significant costs and time delays in this process. In addition, IACUC approved proposals for any work involving controlled substances are necessary to complete the process. PIs should be advised that Federal and State approval for the use of controlled substances may take a year or more to establish at RIT, so PI’s considering their use in research are strongly encouraged to contact the RIT IACUC and the Office of Environmental Health & Safety well in advance of proposed use. 

What facilities exist at RIT? How can I access them? 

There is no vivarium at RIT. This means there is no university-wide core facility solely for care and use of research animals on the RIT campus. Certain departments may have small facilities that are partially dedicated for housing animals at various times throughout the year for teaching and/or research purposes (e.g., the College of Science has a room that houses a small number of animals used in its own teaching labs.) 

Are there alternative sites for animal research? 

The facility at RRH may be available for certain uses and interested PI’s are encouraged to contact RRH when planning proposed research with animals. The current contact at RRH is Jamie Bucher, 585-922-4309.  

Collaborative research involving the University of Rochester Medical center is subject to URMC policies. Questions about animal research should be addressed with the collaborating URMC PI.  

For all proposals submitted to NSF on or after July 31, 2023: All undergraduate students, graduate students, postdoctoral researchers, AND faculty, and other senior personnel supported by NSF proposed research project, must have received RCR training, including training in mentorship. This is a new requirement for faculty to complete the training.

The integrity of research conducted at RIT is of the utmost importance to the institution, as well as to the public and our research sponsors. Our training and education program in Responsible Conduct of Research (RCR) is designed to meet the university's commitment to promoting and supporting the ethical and responsible conduct of research across all disciplines. It is also designed to meet the specific regulatory requirements set by NSF and USDA-NIFA for their funded research. (Those receiving any support thought NIH training and career development grants such as type D,T,F, and K awards should contact SRS to confirm completion of an instructor led RCR training workshop requirement of eight contact hours in RCR to meet their specific sponsor requirements).

Required Training

RIT meets the RCR training requirements by all students, postdoctoral researchers, staff, and faculty supported by the NSF research to complete RCR training in discipline closest to their research as provided through the Collaborative Institutional Training Initiative (CITI) training RCR modules.  Once completed this RCR training is valid for period of four years. This required RCR training will be required by all named project key personnel prior to issuance of a NSF funded account.

RIT’s RCR Plan

1. Project PI’s will ensure all students and postdoctoral researchers on the project receive an electronic or paper version of the RIT handout "An Introduction to Resources on the Responsible and Ethical Conduct of Research"
2. All project staff supported by NSF or USDA-NIFA must complete online training in Responsible Conduct of Research at the Collaborative Institutional Training Initiative (CITI).  Training and completion records are available via this CITI portal, and they will automatically integrate with the Novelution sponsored research system to document completion of the requirement in the research project records.
3. PI’s will be responsible as part of their supervision and mentoring duties on the research project to discuss any RCR issues that are related to the project with all their students and postdoctoral researchers working on the project. These mentoring discussions may consist of informal or formal meetings to discuss research topics related but not limited to: the conduct of the research project and writing about the results, specific ethics issues that arise in the project or in this type of research, preparing publication and presentations, responsible professional data management practices, and any other topics mentioned in the “Introduction to Resources on the Responsible and Ethical Conduct of Research.”
4. PI’s will certify that they will meet these requirements as part of their terms and conditions summary documents for each NSF or USDA-NIFA award.

All student participants of an NSF Research Experiences for Undergraduates (REU) site award will receive their RCR training as part of the REU site curriculum and orientation by the site leaders.

Instructions for logging onto CITI website and completing RCR tutorial

• Go to  www.citiprogram.org
• Go to Create Account and click "Register"
• In the "Select your Organizational Affiliation" menu, enter "Rochester Institute of Technology".
• Create your username/email address to be your exact RIT email address (no alias or personal email address)
• Select the "Learner group" based on your field of research.
• Select the Responsible Conduct of Research (RCR) module to be course closest to your field of research, and make sure it is a RCR course with RCR term clearly in the title of the course.
• If you used your exact RIT email address, your completion record will automatically update in your Novelution Sponsored Research Module profile.

New or renewal proposals to NSF submitted after January 30, 2023  require that PIs take an additional step to safeguard participants when engaging in off-campus research activities.   Off-Campus means sufficiently distant from campus such that access to certain campus resources is limited.  Standard work-from-home, day trips, and limited excursions where there is no overnight stay do not require special steps by RIT or the PI.  In addition, attendance at a conference for presentation of research results does not require any additional steps.  If off-campus research conduct or collecting events are to occur, then PIs must: 

1. create a plan for a safe and inclusive work environment, and
2. distribute that plan to each participant -- in advance of departure for an off-campus research activity.

To reduce administrative burden on faculty, SRS has created information that includes a template plan that already references core University policies and procedures information as well as fields for PIs to complete their project-specific information required by the NSF. 

At RIT, even when off-site, all project personnel must abide by the policies and procedures set forth in RIT’s Policy C6.0 Policy Prohibiting Discrimination and Harassment,  C.27.0 Policy on Title IX Sexual Harassment for Faculty Staff and Students, and D.19 Student Gender-Based and Sexual Misconduct.  For more information, or to file any report, please see the RIT Title IX Office website.   

Common questions and answers about this NSF policy and RIT’s response

All programs or activities with minors (generally anyone under 18) at RIT, including any sponsored research programs, must be registered with the Office of Youth Protection and Compliance with sufficient advance notice to meet requirements of the RIT Protection of Minors Policy (HYPER Link C26.0).

• A Program Organizer is required to be identified for any RIT program or activities with minors
• The Program Organizer is responsible for a program’s compliance with the RIT Protection of Minors Policy, including but not limited to program registration, ensuring program staff compete required screening and understandtheir responsibilities for youth protection, ensuring there is appropriate supervision of minors throughout the program, and ensuring program staff understand theiresponsibility to report incidents or concerns.
• An individual’s role with a program, as well as the type of activity, determine which elements of the screening process are required before an individual may begin interacting with minors in that program.
• All PI’s should be aware of this policy and its requirements.

This registration process must be completed through the RIT Youth Protection Portal (YPP) https://www.rit.edu/k12/information-rit-employees-and-students.  All programs must be registered by the respective program organizer, a program representative, or the individual representing RIT in a non-RIT activity.

Any questions should be directed to the Office of Youth Protection and Compliance at youth@rit.edu.