NSF Safety Plan FAQ

Frequently Asked Questions

Where can I find the new NSF safety plan requirement?

The "Safe and Inclusive Working Environments for Off-Campus or Off-Site Research” requirement can be found at NSF PAPPG, II.E.9.   AORs must certify that an organization has a plan in place for safe and inclusive research for any proposal that proposes to conduct off-campus or off-site research.

How does NSF define “Off-Campus or Off-Site Research”?

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.”
 

There used to be a manual PDF form for the PI to complete with every NSF proposal.  What changed?

When PSU first became aware of this requirement, there was not much time to prepare for an automated solution to collect the needed information, thus we needed to quickly implement the use of a manual form to ensure that we remained compliant.   OSP continues to work with the ORIS team to develop a phased-solution to automate the collection of the required documentation.

The first phase of the automated solution was released on 9/6/2023 in which the Principal Investigator will be required to answer the off-campus/off-site research question on the Investigator’s tab in the IAF for any proposal where the sponsor or prime sponsor is NSF.

• If the PI answers NO, they will be required to complete an assurance statement stating that they will contact the Office of Equal Opportunity and Access if an off-campus or off-site component is later added to the project.  This assurance statement is completed directly in the IAF and no further action or manual forms are required unless there is a change.
• If the PI answers YES, they will be provided with a link to instructions on how to complete the required plan.

Future phases of the automated solution may include incorporating the safety plan components directly into the IAF (eliminating the manual form completely), automatic routing and approval from the Office of Equal Opportunity and Access, and notifications of the addition of project personnel on projects requiring a plan.

Who is responsible for uploading the applicable safety plans?

If the IAF has not yet been submitted to the CPO, the research administrator who is assisting the Principal Investigator with their proposal, or the AOR, should upload the applicable safety plan.  

In general, once the IAF has been submitted to the CPO, the CPO should upload the OEOA-approved plan via Document Manager.

The PI submitted their draft plan to the Office of Equal Opportunity and Access for review and approval, but they haven’t received the approved plan yet.  Do I need to wait to receive the approved plan before submitting the proposal?

No.  AORs can submit proposals without an OEOA-approved plan since this plan is internal to PSU and is not required to be submitted to NSF.  However, any resulting awards will not be processed and no work can commence on the project without an approved plan. 

If the answer entered into the IAF is “NO” to off-site research, there is no upload required, correct?  (i.e. “NSF Safety Plan – NA” is no longer needed)

Correct.  By virtue of the PI answering NO in the IAF itself, it means that the certifications are collected within the IAF and there is no manual form to upload.  The only time there would be an upload of “NSF Safety Plan – NA” is when the PI’s “NO” answer to the off-site question was not collected within the IAF itself.  The manual form would be needed to collect the PI’s certification.

The CPO returned an IAF back to my College for a revised budget, and the IAF is now requiring the PI to answer the off-campus/off-site research question.  Why is this happening?

If the original proposal was submitted to the CPO prior to 9/6/2023, the question was not asked or answered in the IAF because that functionality did not exist prior to 9/6/2023; we may have collected this information on the manual form.  Upon return of the IAF to the College for any reason, the IAF system will know if the question has not been answered and will at that time prompt the PI to answer before it can be resubmitted back to the CPO.  If the project involves off-campus of off-site research, and a plan was already completed, approved and uploaded, no further action needs to be taken.

Supplemental proposals:  I am preparing a supplemental proposal to an original proposal that was submitted prior to the requirement effective date of January 30, 2023.   Will the PI need to answer the off-campus/off-site research question in the IAF?

 Yes.  Supplemental proposals are new proposals and subject to the NSF requirement.  The PI will need to answer the question in the IAF, and complete a safety plan if applicable to the project.

Subaward proposal to PI’s previous institution:   PSU has a new faculty member who is submitting a subaward proposal back to their previous institution for funding their portion of an existing award.  Would this require the PI to complete a safety plan, if applicable, if it was ‘awarded’ before the plan became required?

It depends on the specifics of the prime grantee’s award and whether or not there was a requirement contained in their solicitation or award terms and conditions.  In most cases, the subaward we receive from the prime grantee will likely include the requirement in the award terms and conditions.  Absent this, it would be best to seek specific guidance from the prime grantee about whether or not PSU is subject to the requirement.   When in doubt, please consult with your CPO.