International Research and Export Control Office
Description
In many cases, the university has additional departments or committees that must review and approve research in addition to the IRB and OPRS. This is part of the Human Research Protection Program (HRPP), more information can be found here: https://oprs.research.illinois.edu/about/human-research-protection-program
The Office of Research Security and Export Control Office are a part of the HRPP. It is important to note that these reviews and regulations are outside the scope of the IRB, but researchers are required to follow all federal regulations and institutional policies to conduct human subject research.
Certain situations will require additional review before the IRB and OPRS can conduct their review of the research. General guidelines are provided to OPRS and researchers about when the additional review is required, but all determinations related to these policies are made by the Export Control Office or other related departments.
Research conducted with citizens or “people who are normally residents” of certain countries may be subject to various sanctions by the United States government or other regulations. Neither the researcher nor the research participant needs to be physically located in the country to require review by the Export Control office. In this context, “people who are normally residents” of a country includes individuals who are from the listed country and are not citizens or permanent residents of a different country. For example, a project involving surveys or interviews of Cuban immigrants living in the United States will require additional review if those immigrants are not US citizens or legal permanent residents of the US.
As such, any human subject research project that targets participants who currently live in, or are normally residents of, one of the impacted countries must be reviewed and the research plan approved by the Export Control office prior to IRB/OPRS review and approval. The list below is provided as a courtesy and may be updated at any time. Additionally, the Export Control office is the authority on which countries require additional review.
The impacted countries are:
China
Cuba
Iran
North Korea
Russia
Russian-occupied Ukraine
Syria
OPRS Process:
- PI submits application via IRBOnline
- OPRS staff identifies targeted participants as citizens of, or people who are normally citizens of, one of the impacted countries.
- OPRS staff will return the application with a revision request to the research team providing instructions for the research team to contact the Export Control office.
- Once the Export Control office review is completed, the research team/PI will attach notification from the Export Control office to the IRB application in #23.7 and re-submit the IRB application to OPRS to begin the OPRS review process.
*Please note that research involving participants physically located in mainland China at the time of participation is also subject to review by the PIPL Research Oversight Committee prior to IRB/OPRS review. More information can be found here: https://research.illinois.edu/committees/pipl-research-oversight-committee-p-roc