University of Pennsylvania Research Resumption Phase: Spring Semester
Effective: January 11, 2021
As we look forward to the new year, minor modifications to the Research Resumption Plans are warranted. The Spring Semester Phase of Research Resumption continues the requirement that occupation density is restricted by compliance with 6’ social distancing in the laboratories or research spaces, as well as in the associated open spaces. The majority of the requirements in the Phase II and the Fall Semester Phase remain in place. 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. Expansion of undergraduate research activity is anticipated upon a required review.
Those engaged in research activities must maintain compliance with national, commonwealth, and city mandates. Additional restrictions that might be imposed can and probably will change over the coming months. These could curtail activities such as meetings and gatherings. The University will regularly update guidance. The Spring Semester Phase is characterized by the below plan.
Mask use is mandatory on campus. Additional specific PPE/mask requirements pertaining to laboratory and clinical research may also apply.
Use of PennOpen Pass (https://pennopen.med.upenn.edu/) is a prerequisite to accessing research spaces. In addition to providing campus access, PennOpen Pass provides guidance for anyone with symptoms, including access to testing and health care providers.
All research activity that can be performed remotely must continue to be performed remotely. This allows for a more depopulated campus for those that must be in the buildings and promotes social distancing.
Social distancing of at least 6’ remains a requirement in all spaces. Therefore, a return to 100% of normal occupancy is not allowed unless the research space and associated general spaces can accommodate the distancing requirements. Faculty research resumption plans should be reevaluated if significant density changes are anticipated.
Regular compliance sweeps by Environmental Health and Radiation Safety and/or school building administrators will continue to monitor the status of social distancing compliance and provide advice on safe practices. A series of escalating consequences is in place for repeated non-compliance.
Positive COVID-19 cases at Penn and any community transmission will continue to be monitored.
Research resumption plans must be developed for schools that plan to begin on-campus research activities in the Spring. 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 (firstname.lastname@example.org), 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. Links to school plans are found on the UPenn Office of the Vice Provost for Research website, https://research.upenn.edu/resources/resumption/
Post Doc and Graduate Student Researchers
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 progress for those with children/elder needs or to enable social distancing requirements when on campus.
Research activity for Penn Undergraduates in the following categories is allowed in select circumstances, including: research activity required/associated with scholars programs, independent study, research assistants, work study, or very limited volunteer research experience. Whenever possible, research activities that can be done remotely, should be done remotely.
Undergraduate research requests must be approved by the school committee or official responsible for evaluating research resumption activities of the laboratory or research space in which the activity will take place. In cases where the research activity occurs in a department or school other than the undergraduate’s home department, the student should discuss his/her plans with his/her advisor and academic program or school advising office. In these cases, the research must also be approved by the appropriate school committee or official responsible for research resumption in the department where the research will occur.
The following should be considerations in the assessment of the undergraduate research request.
The faculty member/PI must be willing to supervise and provide support for the activity of the student and have the capacity for increased population density, while maintaining social distancing in the research spaces.
The associated density change must be compliant with the social distancing requirements in the general spaces.
The faculty member’s research resumption plan must be revised to detail the inclusion and activities of the undergraduate student and be reapproved by the school official or committee. The school official or committee will assess the impact of the activity on population density and social distancing and in the case of limited capacity, will make determinations regarding the resumption of activities.
Any approved in-person undergraduate research is subject to the requirements outlined
in the advisor’s and the student’s school Research Resumption Plans.
Population Density and Social Distancing
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 as well as 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, and weekend access 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.
Use of Meeting Spaces
All activity that can be performed remotely should be performed remotely, including meetings. In person meetings are generally not permissible. 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 from the appropriate school official or committee. Social distancing must be maintained, including at ingress and egress. The research resumption plan must include details regarding why an in-person meeting is required, the room size, number of participants and length of time in the space. The school (building administrator) may be contacted 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.
All research activities must maintain compliance with federal, state and local regulations. At the writing of this policy the Pennsylvania Department of Public Health issued an emergency order restricting meetings and gatherings.
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.
Considerations for field work remain the same as in Phase II and Fall Semester Phase 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
Clinical human subjects research resumption plans are approved by the appropriate school official or committee. Considerations remain predominantly the same as in the Fall Semester Phase. 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. Approvals are no longer required but investigators are encouraged to confirm that the necessary resources are available to support their studies.
If in-person research is authorized by the 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
Non-clinical human subjects research resumption plans are approved by the appropriate school official or committee. Considerations remain the same as in Phase II and Fall Semester Phase. 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. Please see IRB website (https://irb.upenn.edu/) or contact the IRB for more details.
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 refer to the IRB’s dedicated COVID-19 guidance webpage (https://irb.upenn.edu/mission-institutional-review-board-irb/guidance/covid19) for more details under the section entitled Requirements for In-Person Research Resumption.
Close Contact Research
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.
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, EHRS@EHRS.upenn.edu
Faculty, students and staff must be compliant with university testing requirements. For some this requires weekly or biweekly surveillance testing, for others, testing when symptomatic is required. The requirement depends on the activities taking place on campus. These processes are linked to PennOpen Pass, https://pennopen.med.upenn.edu/
PennOpen Pass provides instructions and support for those who test positive. If an individual tests positive for COVID-19:
The individual will not report to campus, will notify his/her supervisor of his/her absence and will be contacted by a contact tracing team.
If an individual tests positive outside of a Penn testing site, PennOpen Pass should be completed, and the supervisor should be made aware of the test results if the individual has been on campus.
The contact tracing team will determine if there were any close contacts (within 6’ for greater than 15 minutes cumulatively) as well has their respective risk of transmission and associated quarantine recommendation.
Individuals deemed close contacts will be asked to quarantine for up to 14 days.
If the COVID-19 positive individual was on campus during the last three days, contact EHRS for guidance on cleaning and potential 24-hour laboratory shut down (if the positive case was present in the laboratory the same day as testing positive).
If more than one person in the same laboratory tests positive within a 7-day period, an exposure control team consisting of representatives from Occupational Medicine, EHRS, contact tracing team, PennOpen Pass and Campus Wellness will convene a meeting to review and assess the situation, and discuss strategies for breaking the chain of viral transmission.