NSF Safe and Inclusive Work Environment for Off-Campus/Off-Site Research

The Marine Biological Laboratory (MBL) is committed to addressing harassment and fostering a safe and healthy work environment. Policies and expectations for proper conduct apply to all staff, faculty, and students whether on-campus or working, doing research, or engaging in scholarly activities or study at an off-site location.

In addition, it is NSF policy to “foster safe and harassment-free environments whenever science is conducted.” (NSF 2023 PAPPG Guide II-E.9]. Grantees are required, effective with proposals submitted 1/30/2023 or later, to certify that there is a plan in place.)

NSF defines “off-campus or off-site research” for the purposes of this requirement as “data/information/samples being collected off-campus or off-site, such as fieldwork on research vessels and aircraft.”

INSTRUCTIONS FOR NSF PRINCIPAL INVESTIGATORS (PIs)

NSF PIs are responsible for:

(1)     Determining whether any “off-campus or off-site research” will occur on their NSF-funded award (see definition below). Plans are only required for NSF-funded awards containing research that is conducted off-site or off-campus. See the associated FAQs for more information;

(2)     Completing the project specific information on the last page of this document and;

(3)     Distributing both pages (“the plan”) to everyone who will participate in an off-campus or off-site research activity prior to those individuals leaving campus to engage in the off-site or off-campus research;

(4)     Retain documentation of the plan and the plan recipients (email or signup sheet is sufficient).  This documentation must be forwarded to the MBL Office of Sponsored Programs (Email MBL OSP) and will become part of the Award file.  Plans may be re-used and re-distributed for multiple off-campus research activities but must be updated if the specific content needs to change.

MBL PLAN AND RELATED POLICIES

NSF Safe and Inclusive Work Environment for Off-Campus/Off-Site Research Plan 

The Marine Biological Laboratory (MBL) is committed to addressing harassment and fostering a safe and healthy work environment. Policies and expectations for proper conduct apply to all staff, faculty, and students whether on-campus or working, doing research, or engaging in scholarly activities or study at an off-site location.

In addition, it is NSF policy to “foster safe and harassment-free environments whenever science is conducted.” (NSF 2023 PAPPG Guide II-E.9]. Grantees are required, effective with proposals submitted 1/30/2023 or later, to certify that there is a plan in place that addresses:

(1)  Abuse of any person, including but not limited to harassment, stalking, bullying, or hazing of any kind, whether the behavior is carried out verbally, physically, electronically, or in written form; and                                                                          

(2) Conduct that is unwelcome, offensive, indecent, obscene, or disorderly.

The MBL meets NSF requirements by using the policies and procedures outlined below, and as described by the PI to cover special circumstances in the project-specific information shown in this document. Principal Investigators are responsible for distributing a copy of this plan to each participant in off- campus or off-site research prior to those individuals leaving campus to participate in off-campus or off-site activities.

KEY POLICIES AND PROCEDURES

All MBL staff, faculty and student workers are required by MBL policy to complete Harassment Training, more information can be found HERE. In addition, the MBL has a robust policy system designed to enforce the expectations for a safe and healthy work environment. The following is a list of applicable policies. (Note that the hyperlinks are publicly accessible.)

• Code of Conduct
• Ethics and Compliance Hotline Reporting Policy
• Allegations of Misconduct
• Scientific Integrity
• Minors in Research Laboratories and/or Other Research Activities
• Unlawful Harassment Policy
• Equal Opportunity, Affirmative Action, and Diversity  
•  Violence Prevention

REPORTING SUSPECTED MISBEHAVIOR

FAQ’s

(1) What constitutes off-campus or off-site research? Under what circumstances would a location be considered off-campus or off-site?

Off-campus or off-site research is defined by NSF as data/information/samples being collected off-campus or off-site, such as fieldwork and research activities on vessels and aircraft.  The MBL further defines the intent of this requirement is to provide guidance and protection for participants when they do not have ready access to usual on-campus in-person resources. If your participants continue to have such access, no plan is needed. If participants are sufficiently distant from campus that access to these resources is more limited than they would be if they were on campus, then a plan is likely needed.

(2) Who counts as a “Participant”? Does this include subrecipient personnel? Or other faculty working at the off-campus location with the PI?

It includes all Marine Biological Laboratory (MBL) participants. 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.) The MBL’s plan may be shared and adapted for use by the subrecipient. Typically, a MBL PI will only assume responsibility for MBL participants but there may be cases where guests or participants from other entities may need to use the MBL’s plan. This is allowed, but places a special administrative burden on the MBL PI, as these participants will not already be familiar with MBL’s policies or practices, and special coordination across entities may be needed. It is a good idea to confer with OSP well in advance of the off-site research should this be applicable so that special arrangements can be created.

(3) What are “research activities”?  I don’t do research; my NSF work is considered an “other sponsored activity”.

This new requirement applies only to research activities. NSF has defined off-campus or off-site research for the purpose of this 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 an award has a research component that is characterized as an “other sponsored activity”, then the requirement would apply only to that research component.

(4) For projects that propose to conduct research off-campus or off-site, must the safe and inclusive working environment plan for that proposal be completed and on file with the proposing organization prior to proposal submission?

Yes, the plan for that proposal must be completed and on file prior to submission. By signing the cover sheet, the AOR is certifying there is a safe and inclusive working environment plan in place for that proposal.

(5) Must the safe and inclusive working environment plan be submitted to NSF at the time of proposal submission or post-award, should the proposal be funded?

The plan does not need to be submitted to NSF for review, unless otherwise specified in the program solicitation, or requested by NSF.

(6) Our organization is working on a proposal where we are the lead, and the non-lead is planning to work off-site/off campus for part or most of the project. Do we as the lead organization need to check the Off-Campus or Off-Site Research box on the cover sheet when we do NOT have plans to work off-site/off campus for our portion of the project?

The lead organization must check the Off-Campus or Off-Site Research box on the cover sheet if either the lead or any non-lead organization proposes to conduct research off-campus or off-site.

(7) I am submitting a separately submitted collaborative proposal to a program solicitation that requires the safe and inclusive working environment plan be submitted at the time of proposal. The non-lead organization will be conducting off-campus or off-site research, however the lead will not. Which organization should upload the plan into Research.gov?

In situations where a program solicitation requires submission of the safe and inclusive working environment plan at the time of proposal, consistent with how postdoctoral mentoring and data management plans are handled, the plan should be uploaded by the lead organization. Only the lead organization must check the box on the cover sheet if either the lead or any non-lead organization proposes to conduct research off-campus or off-site.

(8) How does the safe and inclusive working environment requirement apply to a collaborative submission when multiple organizations will be conducting off-campus or off-site research? Are non-lead organizations required to each have their own plan, or is a single plan sufficient for all collaborating organizations?

The safe and inclusive working environment requirement to have a plan in place as stated in PAPPG Chapter II.E.9 applies to all lead and non-lead proposals that propose to conduct research off-campus or off-site. If more than one collaborating organization proposes to conduct research off-campus or off-site, one joint plan must be developed, unless otherwise specified in a program solicitation.

(9) We are a subawardee or have a subaward on the project, where the prime will be conducting off-campus or off-site research. Is there an expectation that the safe and inclusive working environment plan be included in the subawardee agreement if the subawardee is participating in the off-campus or off-site research?

It is the prime’s decision on whether or not the plan should be included in the subawardee agreement. Since the prime will be conducting off-campus or off-site research, they must develop a safe and inclusive working environment plan. The prime’s plan must be disseminated to individuals participating in the off-campus or off-site research prior to departure, including any participating individuals from the subawardee organization.

(10) For a student or researcher who may make multiple trips to the same site, does the research team have to send the plan for each trip?

One plan covering multiple trips to the same site is sufficient. The plan can be reviewed annually and updated if/when there are substantive changes. An example of changes could be conducting research at a location that is different from the previously indicated in the plan, etc.

For a full list of NSF FAQ's click here.

EXAMPLES of MBL SCENARIOS REGARDING OFF-CAMPUS/OFF-SITE RESEARCH 

 Scenario 1:  A student goes to Sippewissett Marsh for 3 hours on a Tuesday to collect samples. The student returns to the MBL for the rest of the workday. Is a plan required in this situation?  Answer: No, using a local off campus field site (i.e., no overnight travel) would not require a Plan under NSF policy for two basic reasons a) this is a trip to a local field site as part of their routine course/research activity b) a trip without overnight stay do not require plans.   

For questions Email MBL OSP

Or additional information contact:
Diane Cook
Director of Sponsored Programs
Email Diane Cook