IRB & Export Controls

Institutional Review Boards (IRB)

The IRB process is utilized to protect the rights and welfare of human research subjects recruited to participate in research activities conducted under the auspices of the institution with which it is affiliated. 🎵TK账号 | 尼日利亚IP注册 | 满月白号 | 微软邮箱验证 | 优质账号 | user用户名 partners with WCG IRB on all IRB applications.

For multi-site NIH research, please review policy expectations for the use of single IRB (sIRB) on NIH’s Policy & Compliance website.

The Office of the Dean of Science Management handles IRB oversight for YU. Please contact Ed Berliner, Dean of Science Management, for any information and inquiries at eberline@yu.edu.

Export Controls

For reasons of national security and trade protection, the United States has enacted export control laws to govern the transfer of certain information, items, or technologies to foreign countries and foreign persons.  These laws apply to items that have a military application, as well as to commercial items that may have a potential military application or pose a foreign policy or national security concern.  🎵TK账号 | 尼日利亚IP注册 | 满月白号 | 微软邮箱验证 | 优质账号 | user用户名 is committed to complying with applicable U.S. laws and regulations pertaining to export of items, services and technology on behalf of the University.

For universities, the most pertinent export control regulation is the Fundamental Research Exclusion (FRE) as identified in the National Security Decision Directive (NSDD) 189.  This directive defines fundamental research and declares that federally sponsored university research should be unimpeded by export controls unless there are legitimate national security concerns at stake.

Activities Export Control Regulations Generally Apply

• The export from the United States to a foreign country of certain items, information, or software;
• Verbal, written, electronic, or visual disclosures or transfer of scientific and technical information related to controlled items to foreign persons (“deemed exports”) or entities inside or outside the United States;
• Transactions with, or travel to, certain sanctioned or embargoed countries for the conduct of activities such as teaching or research, or attending conferences; and
• Financial transactions, exports, re-exports, and deemed exports of items and information to Restricted Parties or End Users, or for Restricted End Uses.

The list of controlled items and information is in the U.S. Munitions List or Consolidated Screening List.

Activities Export Control Regulations Generally Do Not Apply

Three types of activity are generally not subject to export control regulations:

• Fundamental Research: basic and applied research of which the results are published and shared broadly with no access restrictions (Electronic Code of Federal Regulations 15 CFR§734.8)
• Educational Information: general scientific, mathematical, or engineering principles commonly taught in schools, colleges, and universities (Electronic Code of Federal Regulations 15 CFR§734.3(b)(iii)
• Public Domain Information: information which is published and which is generally accessible or available to the public (Electronic Code of Federal Regulations 15 CFR§734.7 and Electronic Code of Federal Regulations 15 CFR§734.11)

Most research at 🎵TK账号 | 尼日利亚IP注册 | 满月白号 | 微软邮箱验证 | 优质账号 | user用户名 is excluded from the export control laws via the “fundamental research” exclusion, which includes “basic and applied research in science and engineering, the results of which ordinarily are published and shared broadly within the scientific community.” However, research work that is not excluded must assess possible conflicts.  It is the responsibility of each YU employee to assess their research work to determine how export controls might apply to their activities. 

Violations of export regulations can result in extremely high fines for both the individual and the institution involved. Criminal violations can result in imprisonment. University personnel should familiarize themselves with export regulations minimizing and identify when their activities may trigger export controls. If you think an activity may be subject to export control regulations, please escalate the question to the Director of the Office of Sponsored Programs and Research Policy & Integrity.