Letter from the Dean
TO: All UMass Chan Medical School Faculty and Staff
FROM: Terence R. Flotte, MD, Celia and Isaac Haidak Professor of Medical Education
Dean, Provost and Executive Deputy Chancellor
RE: Export Control Compliance
DATE: April 5, 2011
The UMass Chan Medical School (UMass Chan) complies fully with export control and trade sanctions laws and regulations. These laws and regulations are administered by various Federal agencies including Commerce, State and Treasury departments. Export controls are United States laws that regulate and restrict the release of critical technologies, technical data, software code, equipment, chemical and biological materials, and other materials, information and services to foreign nationals and foreign countries. Compliance with these laws and regulations is important as willful disregard and even accidental or innocent violations can result in significant institutional penalties to our institution and individuals.
To ensure the Medical School is in compliance with export control laws and regulations a task force, under the leadership of the Vice Chancellor for Administration and Finance, has been working to review, update and codify UMass Chan procedures that are relevant to its compliance with export controls and trade sanctions. The Task Force includes key representation from the Office of the Vice Provost for Research, Global Health, Faculty Council and central administrative departments. This task force is developing and will issue a comprehensive institutional Export Control Compliance Policy (ECCP) as well related procedures for complying with the ECCP. In addition, along with broad dissemination of the ECCP in the coming weeks, training will be provided for faculty, staff and students.
While the task force proceeds with vetting the ECCP with all appropriate parties, I am sending this communication to assure you that UMass Chan is committed to complying with export control and sanctions laws and regulations. If you have any questions in regards to export controls and compliance, you may call the Office of the Vice Chancellor for Administration and Finance.
Two important questions in considering whether items or technologies are subject to export control laws include what is being sent and where it is being sent. Common items or technologies at UMass Chan that may be subject to export control laws include certain microorganisms and computers. Lists of the restricted materials subject to export control are available online. [Editor's note: The restricted materials list can be found on the Bureau of Industry and Security website http://www.bis.doc.gov; see especially The Commerce Control List section of Exporting Basics.]
Responsibilities of faculty, staff and students include:
- Securing the research and technology, chemicals and biological materials handled, and proprietary and Government articles entrusted to the faculty member against unauthorized use or theft.
- Screening any potential foreign research collaborator and foreign visitor against “Lists to Check” to ensure said person is not embargoed or sanctioned and to ensure the proposed end use is appropriate, see http://www.bis.doc.gov.
- Ensuring any physical good or material being shipped or transferred to a foreign country is not on the Commerce Control List (CCL) of the Export Administration Regulations (EAR), see http://www.access.gpo.gov/bis/ear/ear_data.html#ccl.
Faculty, staff and students are expected to contact the Office of the Vice Chancellor of Administration and Finance with any questions about the application of U.S. export controls or trade sanctions to their research or other activities. Faculty, staff and students should report any potential violations to the Office of the Vice Chancellor of Administration and Finance.
For the most current information on export control and trade sanctions regulations, see www.bis.doc.gov (EAR), http://www.pmddtc.state.gov/ (ITAR) and http://www.treas.gov/offices/enforcement/ofac/ (OFAC).