研究计划的问题

当ORSP审查每一个研究项目时, it examines the proposal 和 accompanying documentation for any potential export control issue that must be resolved before the researcher commences the research project.

• 外国赞助商的研究

  University personnel responsible for negotiating contracts with foreign sponsors or researchers participating in such research should be aware of the requirements of the 反海外腐败法 还有抵制问题.

• 校外研究讨论

  在一般情况下, the majority of exchanges between researchers off-campus can go forward without the requirement of an export license w在这里 the sole purpose of the meeting is to present research findings that have been published provided they do not concern detailed information regarding defense articles that are found on the 弹药列表. International conferences 和/or presentations of research such as in meetings between researchers 和 industry which are limited to published or publishable research are covered by the "publicly available/public domain" exclusions provided by the regulations, 和 no export license is needed when these discussions take place during participation in these conferences. 然而, w在这里 t在这里 is the possibility of exchange with a foreign national or foreign entity of technical information not yet published regarding a defense article found on the 弹药列表, 研究者应该意识到以下几点:

  The International Traffic in Arms (ITAR) regulations only permit unlicensed export of:

  1. 国防物品的一般系统描述
  2. 正规赌博十大平台排行功能或目的的基本营销信息
  3. 一般科学信息, 数学或工程原理，通常在学校教授, 学院和大学
  4. 公共领域的信息(1).e., 在报摊和书店有售, through subscriptions which are available without restriction to any individual who desires to obtain or purchase the published information, at libraries open to the public or from which the public can obtain documents, 通过任何专利局提供的专利, 通过在会议和研讨会上的无限制分发, 贸易展, 或向公众开放的展览.S.; 和 through fundamental research in science 和 engineering at accredited institutions of higher learning in the U.S. w在这里 the resulting information is ordinarily published 和 shared broadly in the scientific community.)

  Technical information which falls within the meaning of the first categories above 和 is NOT ITAR-controlled includes top-level drawings, top-level narrative descriptions or summaries of performance requirements, 关键子系统, 设计能力或制造设施. 同样的, 可靠性分析的顶层描述, 顶层框图, 操作模式的顶层描述, top-level equipment layout drawings 和 top-level predictions of power usage or consumption do not require a license.

  然而, 可能是itar控制的技术信息, 和 thus require an export license before sharing with a foreign national or foreign entity, 包括有关“如何”设计的详细信息, 制造 和 test; design, 制造, test methodology or philosophy; technical trade-off methodology or detailed alternatives, 详细的测试数据或测试程序, 集成和测试计划的详细描述, 或详细的原理图或接口信息, as well as manufacturing or assembly processes or analytical methods of procedures.

• 与校外外国实体的通信

  研究ers should also be aware that exports of all other technical information about a defense article can take place either through exchange of documents, 通过面对面的口头交流或电话交流, 或通过电子交流，包括传真或电子邮件.

  此外, ITAR禁止提供援助, 包括培训, 与外国人的防卫物品有关的.

  可能引起出口关注的情况:

  1. Emailing a colleague in a foreign country unpublished technical data about a controlled item.
  2. Sending a draft of a publication to a foreign colleague to review that contains unpublished controlled technical data.
  3. Providing information to a foreign colleague linking two or more publications regarding controlled equipment or technology. A "defense service" may be provided by the simple act of linking the two publications.
• Deliverables to Foreign Sponsors or Transfer of Export-Controlled Material or Information Outside the U.S.

  在研究过程中开发的设备(i.e., a prototype) or related technical data is to be sent off-campus to a foreign sponsor, it must be reviewed to determine whether an export license is necessary.

  As a license will generally require a minimum of 6-8 weeks to acquire, a researcher should also consider whether purchasing the controlled equipment abroad is possible or alternatively whether the equipment can be shipped directly from the company to the foreign research site, as it is the party exporting the equipment who is required to secure the export license. 然而, 即使设备是由另一方出口的, the researcher should also be careful not to export "technical assistance" or "defense services" in the form of controlled information, such as technical specifications or instructions on how to use the equipment. 在某些情况下, providing this information may also require a license 和 ORSP should be contacted before doing so to evaluate whether a license is required.

  例子:

  A researcher receives controlled materials from a foreign sponsor 和 then is required to return the controlled materials, 原形的:原形的或在研究过程中修改过的. No license is required to receive the materials as it is an import, not an export. 然而, an export license may be required, 和 this must be evaluated by ORSP 在材料被退回之前.

• 接收出口管制资料

  As more funding sources become aware of the potential for export control issues to arise in a research project, they may attempt to impose export control restrictions on the research they are funding, which may be unacceptable to the 正规赌博十大平台排行 if such restrictions destroy the fundamental research exclusion.

  例如, if a research proposal indicates that it will be necessary for export-controlled information to be received by the researcher from the sponsor or a third-party in order to perform the research, this may create restrictions on publication 和/or the use of foreign nationals in the research. 为了维护基础研究的排除, it is preferable that no export-controlled information be necessary for a research project to go forward, 但如果是的话, the 正规赌博十大平台排行 requires that the party providing the information be responsible for identifying the information as export-controlled 和 implementing any necessary controls, often in the form of a non-disclosure agreement that will address the export concerns.

  If the researcher or administrator has reason to believe that information to be received is export-controlled information, it is imperative that the researcher contact ORSP which can clarify whether t在这里 is cause for concern for export-control purposes 和 determine whether the researcher is able to receive the information before accepting it.

• 可能与军火有关的技术或设备

  W在这里 a research project is to develop technology or equipment that may have a military application, the administrator should review closely the Statement of Work to first evaluate the nature of any export controls on the equipment. 它很有可能在 弹药列表 和 that a license may be required if any equipment or technology is a deliverable to the sponsor.

  As a license will generally require a minimum of 6-8 weeks to acquire, a researcher should also consider whether purchasing the controlled equipment abroad is possible or alternatively whether the equipment can be shipped directly from the company to the foreign research site, as it is the party exporting the equipment who is required to secure the export license. 然而, 即使设备是由另一方出口的, the researcher should also be careful not to export "technical assistance" or "defense services" in the form of controlled information about the equipment such as technical specifications or instructions on how to use the equipment. 在某些情况下, providing this information may also require a license 和 ORSP should be contacted before doing so to evaluate whether a license is required.

  例子

  • 开发防弹材料
  • 研究 satellites or research equipment to be sent to a satellite
  • 光学和制导设备，包括GPS设备

  对外国人研究项目的限制

  Agreeing to restrict participation on a research project is against University policy 和 if accepted would create a significant burden on the institution to comply with this requirement. In addition, such a restriction can jeopardize the fundamental research exclusion. If t在这里 is any indication that the participants on a research project are to be limited in some manner, it is necessary to evaluate with ORSP whether the project can go forward.

  例子

  外国国籍限制

  • Contractor must submit employee's eligibility documentation for review 和 approval.
  • All foreign nationals who work on the contract or task order shall be approved by the Contracting Officer before beginning work on a contract/task order.
  • 通过签订合同, the Contractor certifies that no foreign nationals are working under the contract.
• 出版审批限制

  Restrictions on publication can destroy the fundamental research exclusion as well as violate University policy on freedom to publish research results. 这些限制可以在许多地方说明, 例如《正规赌博十大平台排行》, 赞助商的附信或提议的协议. It is very important that they be identified 和 addressed because they are sometimes very difficult to negotiate out 和 may prevent a project from going forward.

  例子

  • 批准出版
  • The contractor shall not release to anyone outside the Contractor's organization any unclassified information, 不管介质是什么(e).g., 电影, 磁带, 文档), pertaining to any part of this contract or any program related to this contract, 除非订约官员事先给予书面批准. (节选自DFAR 252.204-7000)
  • T在这里 shall be no dissemination or publication of information developed under this contract or contained in the reports to be furnished pursuant to this contract without prior written approval of the Contracting Officer.
• 带着笔记本电脑或其他电子产品旅行

  研究ers commonly carry laptops, cellphones 和 tablets with them around the world. It is imperative to know that this means the laptop 和/or cellphone 和/or tablet is being exported. This is true not only when the laptop 和/or cellphone 和/or tablet is abroad, but also when they allow a person in a foreign country to use the laptop 和/or cellphone 和/or tablet or allow a foreign national access to the laptop 和/or cellphone 和/or tablet in the United States.

  研究ers should review the software 和 data they may be carrying to ensure that they are not taking any controlled software or technical information out of the country. 这同样适用于全球定位系统(GPS)。. 包含底层软件 耳朵 在某些情况下， ITAR.

  Export regulations vary based on the country to which a researcher is traveling 和 the purpose for which he or she intends to use the device. 然而, 手提电脑或全球定位系统(GPS)的出口可能适用许可例外, which potentially would enable a researcher to take the equipment abroad without violating either the 耳朵 or ITAR.

  你必须联系 ORSP before using a license exception, as it is subject to record-keeping requirements. 了解有关许可异常的更多信息 在这里.

  联系 资讯科技(IT) 了解更多正规赌博十大平台排行清洁笔记本电脑程序.