Safe & Inclusive Working Environments for Off-Grounds Research

Safe and Inclusive Working Environment Plan NSF Requirement

Per the NSF Proposal & Award Policies & Procedures Guide (PAPPG) (23-1), all proposals submitted on or after January 30, 2023, must have a written plan to safeguard participants when engaging in off-campus or off-site research activities. Specifically, PIs must create a plan for a safe and inclusive work environment - and distribute that plan to each participant- in advance of departure for an off-campus or off-site research activity.

Proposers should not submit the plan to NSF for review unless specifically requested. 

Principal Investigators (PIs) should determine if the proposed research includes any “off-campus or off-site research," as defined by NSF (see below). NSF-funded proposals, and subsequent awards, including off-campus or off-site research activities are required to have a project-specific plan for creating and maintaining a safe and inclusive working environment ("the plan").

PIs are responsible for maintaining and retaining a copy of the plan, as well as documentation of who received the plan (email or signup sheet is sufficient) in RUVA or in PI or departmental grant files. These records are subject to the same retention schedule as other grant-related administrative records.

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.

To reduce administrative burden, UVA has created a template plan that includes instructions, applicable University policy and procedure information, and fillable fields for PIs to complete their project-specific information.

Safe and Inclusive Work Plan:

(Instructions and Plan Template) (Template only)

UVA Related Offices and Policies

UVA Office for Equal Opportunity and Civil Rights  

UVA policies: 

SEC-044 Use and Access of Service Animals, Service Dogs in Training, and Emotional Support Animals on University Property or with Respect to University Programs and Activities

HRM-041 Policy on Sexual and Gender-Based Harassment and Other Forms of Interpersonal Violence

HRM-040 Reporting by University Employees of Disclosures Relating to the Policy on Sexual and Gender-Based Harassment and Other Forms of Interpersonal Violence and the Preventing and Addressing Discrimination and Harassment, and Preventing and Addressing Retaliation Policies

IRM-008 University Information Technology Accessibility

RM-010 Preventing and Addressing Retaliation

HRM-009 Preventing and Addressing Discrimination and Harassment

 

Notice to NSF Proposal Submitters

The National Science Foundation (NSF) requires plans for safe & inclusive off-campus and off-site research, effective January 30, 2023.

A written plan is required per the National Science Foundation’s (NSF) Proposal & Award Policies & Procedures Guide (PAPPG) 23-1 for NSF-funded research; see NSF PAPPG (2023)

The plan must describe how the following types of behavior will be addressed: 

  • 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; or 
  • Conduct that is unwelcome, offensive, indecent, obscene, or disorderly.

Action Required :PIs need to sign and submit a plan as part of the Funding Proposal in ResearchUVA Powered By Huron (RUVA). The plan should be a separate document (pdf) as it will be retained by UVA and will not be submitted to NSF unless requested. Refer to the following guidance from OSP and the Plan Template.

For NSF-funded projects, UVA requires that this plan be:  

  • Developed by the PI using UVA's template and saved by the PI at the proposal stage;  

  • Provided to the Office of Sponsored Programs (OSP) prior to a NSF award being setup; and  

  • Implemented by the PI. (Reference: NSF Proposal and Award Policies Procedures Guide (PAPPG) 23-1 Chapter II. E.9.). 

  • If a NSF directorate requires the plan (see below) as part of the proposal documents, PIs must use the template and do not need to provide the plan to OSP separate from the proposal.   

Subaward and Collaborative Proposals 

  • If UVA is a subaward recipient on an NSF-funded project with off-campus/off-site research, UVA does not require PI to complete a plan. UVA relies on the lead institution to provide and implement the plan. 

  • For Collaborative Proposals, each institution is responsible for their own plan with regard to any off-campus or off-site performances their organization is facilitating. 

Background Information 

It is NSF policy (NSF PAPPG, Chapter XI.A.1.g.) to foster safe and harassment-free environments wherever science is conducted. NSF’s policy recognizes that a community effort is essential to eliminate sexual and other forms of harassment in science and to build inclusive scientific climates where people can learn, grow, and thrive. 

Grantees are required, effective with proposals submitted 1/30/23 or later, to certify that we have a plan in place for each project with off-campus or off-site research 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 

  1. Conduct that is unwelcome, offensive, indecent, obscene, or disorderly. 

As of January 2023, several solicitations from NSF’s BIO and GEO directorates will pilot requiring the submission of a Safe and Inclusive Work Environments Plan that will be considered as part of the Broader Impacts criteria during the review process. A two-page supplementary document must address: 

  1. a brief description of the field setting and unique challenges for the team; 

  1. the steps the proposing organization will take to nurture an inclusive off-campus or off-site working environment, including processes to establish shared team definitions of roles, responsibilities, and culture, e.g., codes of conduct, trainings, mentor/mentee mechanisms and field support that might include regular check-ins, and/or developmental events;  

  1. communication processes within the off-site team and to the organization(s) that minimize singular points within the communication pathway (e.g., there should not be a single person overseeing access to a single satellite phone); and  

  1. the organizational mechanisms that will be used for reporting, responding to, and resolving issues of harassment if they arise.   

OSP will require use of the UVA template for this requirement. 

UVA is committed to preventing and addressing discrimination and harassment based on race, color, national origin, pregnancy, sex, age, disability, creed, religion, sexual orientation, gender identity, gender expression, veteran (military service) status, political affiliation, or political philosophy. UVA’s Preventing and Addressing Discrimination and Harassment policy 

All UVA employees who have the authority to hire, promote, discipline, evaluate, grade, formally advise, or direct faculty, staff, or students are considered “responsible employees” and are required to report alleged sexual misconduct (including sexual assault, exploitation and harassment), intimate partner violence (dating and domestic), stalking, protected class discrimination, harassment, or related retaliation to UVA's Office of Institutional Equity and Compliance (OIEC).  

  • The reporting obligation applies regardless of whether the member of the UVA community is the person who was subjected to the misconduct or the person accused of the misconduct.  

  • The reporting obligation applies regardless of where or when an incident occurred, including if it occurred off campus and/or before they were a member of the campus community.  

  • The reporting obligation applies regardless of how the information was conveyed to a responsible employee (whether spoken, written, or through a third party).  

The University meets NSF requirements, as well as its own expectations, by using the policies and procedures cited above, and as further amplified to cover special circumstances as dictated by the PI in the project-specific information shown in this document. Principal Investigators are responsible for distributing a copy of the developed plan to each participant in an off-campus or off-site research prior to departure or involvement in the off-campus activity.

Definition of Off-campus or Off-site Research 

For the purposes of this NSF requirement, NSF defines off-campus or off-site research as data/information/samples being collected off-campus or off-site, such as fieldwork and research activities on vessels and aircraft (PAPPG, Chapter 2: D. 2. a. Proposal Contents). UVA further clarifies off-campus or off-site research for this requirement with the following: 

  • Data/information/samples being collected off-campus or off-site, including at UVA-owned locations away from Grounds, for more than three consecutive days and/or research activities that include an overnight stay. 

  • Data/information/samples being collected off-campus or off-site by any project team member, including team members from subrecipient or collaborating organizations performing research outside their primary place of performance. 

  • Meetings and conferences that do not include data/information/samples being collected are not considered off-campus or off-site research. 

  • Data/information/samples collected by subrecipients or collaborating organizations at their primary place of performance is not considered off-campus or off-site research and does not need to be included in this project plan.

  • Determinations about plan requirements must be based on the location and nature of the activities; this assessment is independent of the F&A rate determination which is based on where the preponderance of the work is performed (see, University policy FIN-009: Facilities & Administrative Rate Application and Exception Process). It is expected that some awards using an On-Campus/On-Grounds F&A rate will include off-campus or off-site research and thus require a plan.  

NSF BIO and GEO Directorates Pilot

Several solicitations from BIO and GEO will soon require the submission of a project-specific Safe and Inclusive Work Environments Plan (SAI Plan) as part of the proposal. The plan will be a 2-page supplementary document and the will be considered as part of the Broader Impacts criteria during the review process. See NSF's website for additional information:

Note: This requirement is separate from the broader NSF requirement that the AOR certify that there is a written project-specific SEI plan (discussed above) for off-campus or off-site research activities.