Published: September 14, 2020
As we developed the research on-campus resumption plan, we envisioned an end point in Phase III that would be the ‘new normal’ for open operations and assumed that the COVID-19 pandemic would be under control. As we look toward the next phase in research resumption on campus, we face a very different situation. Though decreasing now, the metrics in the city, region and nation are not what we had hoped and there is an expectation of challenges throughout the fall. Under these circumstances it is not viable in the near term to transition to Phase III as initially conceived, therefore, the next step in research resumption will be the ‘Fall Semester Phase.’ This Research Resumption Phase provides a framework to continue research on-campus while supporting the health and welfare of the community.
The Fall Semester Phase eliminates the explicit population density limit as a percentage of normal occupancy while still requiring social distancing in all spaces, anticipates some expansion of activities in field work and human subjects’ studies, streamlines the close contact exception process and defines exception criteria for use of meeting spaces.
The majority of the requirements in the Phase II plan remain in place during the Fall Semester Phase. These include the requirements for school and faculty research resumption plan approval, exception approval for research related travel, office use approval, field work approval, and processes for clinical and non-clinical studies involving human subjects. The Fall Semester Phase is characterized by the below plan.
Research resumption plans must be developed for schools that plan to begin on-campus research activities in the fall. These plans require approval by the Vice Provost for Research prior to research resumption. Any significant modifications to previously approved plans should also be submitted to the Vice Provost for Research. An outline of the plan requirements can be found at https://research.upenn.edu/resources/resumption/plan/. The University Compliance Officer, Kimberly Craig (kcraig@upenn.edu), can also provide guidance and support.
Faculty initiating on-campus research should develop a resumption plan. This plan must be approved by the appropriate school official or committee prior to resuming research. Faculty research plans must be revised and re-approved by the school if additional activities are anticipated or procedures are altered.
Participation in research is not optional for graduate students, post docs and other researchers. Trainees must be fully engaged making reasonable progress in their research, whether on campus or at a remote location. All activities that can be done remotely should continue to be done remotely. Full deployment in research does not imply that researchers are required to be on campus continuously.
Our primary responsibility to mentor our students and post docs is critical as they navigate through pandemic related challenges. Faculty advisors, department chairs, graduate group chairs and graduate thesis committees should actively engage trainees to ensure that the scope and goals of their research plans are appropriate given the current evolving circumstances. If reasonable progress in research is fundamentally restricted due to pandemic related challenges, consideration should be given to restructuring research directions. Trainees should be supported by academic processes within the departments, graduate groups and schools as they adapt research plans.
Flexible schedules for research should be encouraged to help accommodate full deployment for those with children/elder needs or to enable social distancing requirements when on campus.
Undergraduate students involved in for-credit research as part of an independent study or a scholar’s program may be allowed in research labs on a limited basis if and only if:
Undergraduate students enrolled in Independent Study should discuss their plans with their major Department/Program. Departments and Programs will serve as the initial point of contact for undergraduates. Permission for undergraduates to engage in in-person research will be granted on a case-by-case basis after review by the Department/Program and the Undergraduate School.
Any approved in-person undergraduate research is subject to the requirements outlined in the advisor’s and the student’s school Research Resumption Plans. The Undergraduate Deans will review all requests and provide approval.
While the population density requirement as a percentage of normal occupancy has been eliminated, social distancing must be maintained during all activities, including entering and leaving labs and in the general spaces within the buildings. The number of people that can be accommodated will depend on the configuration of the space; consequently, it is generally not expected that laboratory occupation will reach 100% of normal operations. Strategies such as extended lab hours, shifted schedules, weekend work will still be required to optimize research progress.
A revised resumption plan must be approved by the appropriate school committee or official before an increase in lab occupation is implemented.
All activity that can be done remotely should be done remotely, including meetings. In person meetings are generally not allowed. Technology such as video conferencing, small room video meetings, including advanced capabilities such as digital white boards, annotation tools, joint screen sharing options, and audio feeds should be leveraged to maximize the effectiveness of virtual meetings and minimize the need for in person meetings.
In cases where in person meeting is essential to research progress an exception can be requested. Social distancing must be maintained, including at ingress and egress. The research resumption plans must include details on the reason an in-person meeting is required, the room size, number of participants, length of time in the space. Contact the school (building administrator) for guidance specific to the space that is proposed for the meeting.
Approval of the exception request and associated resumption plan by the appropriate school official or committee is required.
Penn Affiliated Travel remains suspended. Research related travel for faculty, staff, post docs and graduate students is considered Penn Affiliated Travel and requires the approval of an exception from the appropriate school official or body and by the Committee of Travel Risk Assessment (CTRA). Only essential travel will be considered via a petition during this phase. ‘Essential’ means that the travel must be performed at the time in question and whose goal cannot be accomplished by another means. Information regarding research related travel and the petition process can be found on the Vice Provost for Research website or https://global.upenn.edu/travel-guidance/travel-guidelines-and-procedures
Considerations for field work remain the same as in Phase II and are described in the Field Work section of the University of Pennsylvania Research Resumption Strategy Master Plan, https://research.upenn.edu/resources/resumption/plan/#field. Field research resumption plans must be approved by the appropriate school official or committee prior to resumption of research.
Clinical human subjects research resumption plans are approved by the appropriate school official or committee. Considerations remain the same as in Phase II, with one nuance. Penn Medicine has now resumed all patient care activities. Providing investigational therapies to Penn Medicine patients is an integral part of our practice. As a result, the number of clinical trials that meet the definition of essential clinical trials has increased. Requests for approvals of Non Oncology Clinical Research should be sent to Emma Meagher, MD and Oncology Clinical Research should be sent to Bob Vonderheide.
If in-person research is authorized by your school, the IRB’s ‘Required General Precautions for In-Person Engagement with Research Participants’ should be followed. Additionally, all research teams are expected to inform subjects of the potential risks of in-person contact related to Covid-19 when interacting in person. Please see IRB website (https://irb.upenn.edu/) for more details.
Non-clinical human subjects research resumption plans are approved by the appropriate school official or committee. Considerations remain the same as in Phase II, https://research.upenn.edu/resources/resumption/plan. All work should be performed remotely when possible, taking advantage of video feeds and other technology support. Select research, including research that was previously qualified as exempt, may require prospective IRB approval prior to commencing in-person contact.
If in-person research is authorized, the IRB’s ‘Required General Precautions for In-Person Engagement with Research Participants’ should be followed. Additionally, all research teams are expected to inform subjects of the potential risks of in-person contact related to Covid-19 when interacting in person. Please see IRB website (https://irb.upenn.edu/) for more details.
Some specialized research activities that are critical to research progress involve procedures or training in which contact is closer than that designated in current guidelines. To the extent possible, alternative approaches to the research should be developed, including modifying the research goals and procedures, as well as utilizing video feeds and remote technology when feasible.
Under this Phase the close contact waiver process in EHRS is now discontinued. However, for close contact procedures that are essential and cannot be substituted, exceptions to the social distancing requirement must be included in the research resumption plan, as described below, and receive approval from the appropriate school committee or official.
The research resumption plan should address the type of activity, location of the research, plan to minimize the number of people in the research space, necessity and duration of close contact, ventilation at the location, personal protective equipment use, cleaning protocols and identify those involved in the procedures. The conditions of the exception should be included in the research resumption plan and approval by the appropriate school committee or official is required.
Contact the Office of Environmental Health and Radiation Safety for information on the precautions required to perform close contact research safely at EHRS@EHRS.upenn.edu.
