February 10, 2017 ESCRO approval is required annually. You will receive a reminder email approximately six weeks before your expiration date. To continue approval of your ESCRO project: Complete the Renewal Form (DOC) Have the form signed by your department chair Email all documents to ORIE@wustl.edu
Category: How-Tos
Determine Who Can be a PI on an ESCRO Project
February 10, 2017 PIs are usually Washington University faculty members with appointments of instructor or above. However, postdocs who receive their own funding for research using hESC/hPSC (e.g., fellowship award, internal seed grant) will be the PI on the ESCRO application. The research must be overseen by a faculty member, usually the mentor on the […]
Submit New Stem Cell Project Application
February 10, 2017 Complete the ESCRO Application [DOC]. Attach research plan (required) For department funded research, attach a description of research significance and background, experimental design, and potential outcomes (see ESCRO Research Plan Template [DOC]). For sponsored research, attach awarded grant application(s) that supports this research. If proposing to generate new hESC lines or use hESCs […]
Determine if ESCRO Approval is Needed
February 10, 2017 ESCRO review and approval is needed when any of the following biological materials are used for research purposes: Human embryonic stem cells (hESC) Materials derived from a human embryo, including hESC-derived neural progenitors and other hESC derivatives Other human pluripotent stem cells, including human induced pluripotent stem cells (hiPSC) or their derivatives […]
Find Penalties for Violations
Civil Penalties EAR ITAR OFAC University Up to $120,000 per violation Up to $500,000 per violation Up to $55,000 per violation Individual (PI) Up to $120,000 per violation Up to $500,000 per violation Up to $55,000 per violaton Criminal Penalties EAR ITAR OFAC University Up to $1 million per violation Up to $1 million […]
Know Which Countries, Entities, and Persons are Restricted
Restricted Countries, Entities, and Persons The U.S. Department of the Treasury, through its Office of Foreign Assets Control (OFAC), enforces U.S. embargo and sanction programs that may restrict transactions with certain foreign countries irrespective of whether the exported technology is controlled under the ITAR or the EAR. Sanctions programs vary in severity. In cases where a country is […]
Know Which Types of Items are Controlled
“Dual-Use” Technologies The controlled technologies most commonly found on campus are “dual-use” technologies covered by the Export Administration Regulations (EAR). These are items or technologies with potential for both civilian and military use (the military use may not be obvious). Dual-use items can be found on the Commerce Control List (CCL). Each category on the CCL […]
Determine Agency Jurisdictions Over Exports
Two primary sets of regulations govern the export of controlled technologies: the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR). The ITAR, which are administered and enforced by Department of State through its Directorate of Defense Trade Controls (DDTC), regulate the export of military, space, and satellite technologies. The EAR, which are administered and enforced […]
Define “U.S. Person” vs. “Foreign National”
A “U.S. Person” is defined as a: Lawful Permanent Resident U.S. Citizen Legal Immigrant with a “Green Card” Protected Individual granted asylum or refugee status “Foreign National” includes everyone else, including foreign governments or entities not incorporated to do business in the U.S.
Determine When Export Control Laws Apply
What is export control? Export control laws regulate the export of commodities, related technical data and information, and certain services the federal government considers critical to the national security or domestic economy of the United States. The export control laws also regulate the transfer of controlled technical data to foreign nationals within the United States (“deemed exports”). “Exports” are […]