National Science Foundation - Safe and Inclusive Working Environment Plan for Off-Campus or Off-Site Research
Virginia Tech is committed to addressing harassment and fostering a safe and healthy work and learning environment. Policies and expectations in this regard 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.
Virginia Tech reinforces the National Science Foundation’s (NSF) policy to “foster safe and harassment-free environments wherever science is conducted (NSF 2023 PAPPG Guide II-E.9).” Grant recipients, including Virginia Tech, are required, effective with proposals submitted Jan. 30, 2023 or after to certify that there is a plan in place that addresses:
- Abuse of any person, including but not limited to harassment, stalking, bullying or hazing or any kind, whether the behavior is carried out verbally, physically, electronically, or in written form; and
- Conduct that is unwelcome, offensive, indecent, obscene, or disorderly.
Virginia Tech meets NSF requirements (in addition to its own expectations) by using the policies and procedures outlined below, and as further amplified to cover special circumstances as dictated by the principal investigator in the project-specific information provided in the plan. Principal investigator’s are responsible for distributing a copy of the plan to each participant involved in off-campus or off-site research prior to those individuals leaving campus to participate in the off-campus or off-site activities.
Currently, two NSF directorates Directorate for Biological Sciences and Directorate for Geosciences are requiring that a Safe and Inclusive Work Environment plan be submitted with a proposal. Researchers should review the NSF funding opportunity to which they are responding to determine if a plan should be submitted with the proposal.
NSF “Off-Campus or Off-Site Research” Definition
For the purposes of this requirement as “data/information/ samples being collected off-campus or off-site, such as fieldwork and research activities on research vessels and aircraft.” (PAPPG, Chapter 2: D. 2. a. Proposal Contents) Virginia Tech further defines off-campus or off-site as any research activities conducted in a location that is not owned, leased, or rented by Virginia Tech.
NSF Principal Investigators are responsible for:
- Determining whether any “off-campus or off-site research” will occur on their NSF-funded award. Plans are only required for NSF-funded awards containing research that is conducted off-site or off-campus.
- Completing Virginia Tech’s project specific plan document.
- Distributing all pages of 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.
- Retaining documentation of who received the plan (email or sign up sheet is sufficient) and the plan itself in their grant files or in the departmental grant file.
- All NSF proposals submitted to the Office of Sponsored Progams (OSP) will require that a plan be completed and filed with OSP prior to proposal submission. 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.
Key Policies and Procedure
As a baseline, all staff, faculty and student workers are required to be up to date with trainings on the university’s prohibitions of protected-class discrimination and harassment, including sexual harassment. The Office of Equity and Accessibility provides information regarding workshops and trainings on their website.
In addition, it is the responsibility of principal investigators to have an understanding of Virginia Tech’s policy system designed to ensure safe and inclusive working environments, and to ensure that participating university employees, graduate students, and undergraduate students are aware of these policies and that all participants are current on required trainings.
Policies and Contacts
The following are applicable university policies that either prohibit the conduct described above (Policies) or provide an administrative policy and procedure relevant to the university’s ongoing efforts to ensure safe and inclusive working environments at offsite locations (Other Relevant Policies).
Note: Individual schools and colleges and individual faculty may have additional policies, procedures, or standards in place to address faculty, staff or student conduct. This is not a comprehensive list of contacts. Each off campus/off site situation will help determine the appropriate contacts to list.
- Office of Record: Office for Equity and Accessibility
- Key Policy Stakeholders: Kelly Oaks, associate vice president for equity and access; Harrison Blythe, director of compliance; Katie Polidoro, director of T9 compliance
- Relevant Administrative Procedures: Student Code of Conduct and Anti-Discrimination Complaint Procedures
- Office of Record: Office for Equity and Accessibility
- Key Policy Stakeholders: Katie Polidoro, Harrison Blythe
- Relevant Administrative Procedures: safe.vt.edu
- Office(s) of Record: Division of Student Affairs, Office of Student Conduct
- Key Policy Stakeholders: Frances Keene, vice president for student affairs; Nick Whitesell, director of student conduct; Katie Polidoro
- Relevant Administrative Procedures: General Code of Conduct Concern, Hazing Misconduct, and Faculty Handbook
- Office(s) of Record: Vice President of Operations
- Key Policy Stakeholders: Virginia Tech Police Department, Human Resources
- Relevant Administrative Procedures: See policy and Faculty Handbook.
- Key Policy Stakeholders: Mac Babb (Virginia Tech Chief of Police), Tony Haga (deputy chief of police and threat assessment team (TAT) Chair, Caroline Green (TAT Coordinator)
- Relevant Administrative Procedures: See policy.
- Key Policy Stakeholders: Guru Ghosh, vice president for outreach and international affairs; Don Hempson, associate vice president for outreach and international affairs
- Relevant Administrative Procedures: See policy.
Other Relevant Policies
- Key Policy Stakeholders: College Leadership (assistant/associate deans), Dan Sui, senior vice president for research and innovation) Trudy Riley, associate vice president, director of sponsored programs; Rodney Irvin
- Relevant Administrative Procedures: See policy
Frequently Asked Questions
- Meetings and conferences that do not include data/information/samples being collected
- Data/information collected by subrecipients or collaborative organizations at their primary place of performance
- Work from home by an individual employee
The plan will be part of the merit review process under Broader Impacts. Reviewers will evaluate plans on the following:
- Is there a compelling plan (including procedures, training, and communication processes) to establish, nurture, and maintain inclusive off-campus or off-site working environment(s)?
- Does the proposed plan identify and adequately address the unique challenges for the team and the specific off-campus or off-site setting(s)?
- Are the organizational mechanisms to be used for reporting, responding to, and resolving issues of harassment, should they occur, clearly outlined?
Yes, OSP will submit the proposal to NSF but if the principal investigator does not submit the safe and inclusive work environment plan to OSP within four weeks of the proposal submission deadline, OSP reserves the right to withdraw the proposal as Virginia Tech will be out of compliance with NSF regulations.
In SUMMIT proposal when the researcher marks the question “Will there be any off-site work (fieldwork, going to schools for interviews, etc.) on this project as Required the “Actions” button allows files to be uploaded to Summit.
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). If the off-site research is over, send an email to the researcher’s OSP pre-award associate explaining the circumstances. OSP staff will confer with the principal investigator on appropriate next steps (NSF has not identified what corrective actions should be taken, but most likely it will involve an uninvolved third party checking with the participant to ascertain whether there were any issues that arose while off- campus that made the participant feel unsafe or needed reporting.)
It includes all Virginia Tech participants: employees, students, volunteers, and others working under Virginia Tech’s direction (which might include contractors). For subrecipient personnel, their own institution should have issued a plan for the off-site activity (principal investigators should verify with the principal investigator of the subrecipient organization that this has occurred.) Virginia Tech’s plan may be shared and adapted for use by the subrecipient. Typically, a Virginia Tech principal investigator will only assume responsibility for Virginia Tech participants but there may be cases where guests or participants from other entities may need to use Virginia Tech’s plan. This is allowed but places a special administrative burden on the Virginia Tech principal investigator as these participants will not already be familiar with Virginia Tech 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.
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.
Principal investigators (PI) may devise options they believe are appropriate to the circumstances, but some reasonable options to certain known circumstances might include the following:
- Cultural norms differ in the location where the off-campus/off-site research will take place. PIs may wish to offer a “pre-departure” briefing for participants explaining cultural norms in the off-campus/ 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).
- 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 activity.
- 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.
- 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.).
- 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.
- There is only a single satellite phone (or 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 a confidential call be placed. Consider budgeting for a second phone if that is needed to ensure alternate access can be available. Notify participants of their options accordingly.