January 14, 2010

New NSF Requirement for Responsible Conduct of Research Training

Effective January 4, 2010, when submitting new research proposals to the National Science Foundation, UC Berkeley is required to certify that the campus has a plan in place for providing education and training in the Responsible Conduct of Research (RCR) to all students (undergraduate and graduate) and postdoctoral scholars who will be supported by those grants to conduct research.

The Berkeley campus has implemented plans for this new NSF RCR training requirement at http://rac.berkeley.edu/rcr.html.

The Vice Chancellor for Research issued a campus memo through CALmessages on January 13, 2010. The text of the memo is included below.

From: Graham Fleming, Vice Chancellor for Research
To: Deans, Directors, Department Chairs
Subject: New NSF Requirement for Responsible Conduct of Research

On January 4, 2010, the National Science Foundation started requiring that institutions receiving NSF awards have in place plans to provide undergraduates, graduate students, and postdoctoral scholars supported on NSF grants with training in the Responsible Conduct of Research (RCR). This requirement does not apply to existing awards; only those based on proposals submitted after January 4, 2010. While there is no requirement that training plans be submitted with proposals, we must certify that all eligible students and scholars receive some form of training and provide access to these training plans at the agency's request. Institutions are being provided maximum flexibility in creating and implementing RCR programs to meet this new requirement.

At UC Berkeley, we recognize that there are differences between the education and research experiences of the target groups receiving RCR training, and we have designed programs and choices to meet these different needs. Current planned options for UCB undergraduate students, graduate students, and postdoctoral scholars are listed below.

Completion of these activities alone, however, does not guarantee that students and trainees will internalize the essential elements of conducting research responsibly and ethically. The role of the Principal Investigator and other senior faculty in mentoring students and trainees and in providing other opportunities as a basis for didactic discussion (such as readings, workshops, lectures, and courses) cannot be underestimated. I would welcome your ideas about building a more robust campus RCR program.

Graduate Students and Postdoctoral Scholars
The Office of Research Administration and Compliance (RAC) is offering an RCR Curriculum through the Collaborative Institutional Training Initiative (CITI). This online course will form the basis of training in different discipline fields: Biomedical; Social and Behavioral Sciences; Humanities, Physical Sciences; and, Engineering. Students and trainees may go to https://www.citiprogram.org/default.asp to register for the Berkeley course. Individuals who may have taken Berkeley CITI courses for Human or Animal Subjects may use their same user name and password for the RCR coursework.

Undergraduate Students
RAC has also coordinated with UCOP and other UC campuses to develop a handout on major RCR topics. Academic units may choose to provide the handout to all student employees, not just those supported on NSF grants. This handout is available on the RCR web page (http://rac.berkeley.edu/rcr.html) as a PDF document.

Principal Investigators
For NSF proposals submitted after January 4, 2010, Principal Investigators must certify on a per award basis, that all students and post doctoral scholars supported by his or her NSF award have completed RCR training within 60 days of the individual's becoming supported by NSF funding. PIs must provide such certification to RAC by using the Responsible Conduct of Research (RCR) Training Certification Form available at http://rac.berkeley.edu/rcr.html. This document must be submitted to RAC, c/o Rebecca Armstrong - RCR Coordinator, within 90 days of the award being made; and, annually thereafter on the anniversary date of the award for the duration of the project updating any additions of students and postdocs since the last report and certifying that training has occurred as required. This original record will be kept with the SPO award file for the project. PIs should keep a copy for their own records.