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If you hold an academic appointment in the Faculty of Arts and Sciences, this booklet contains important policies that govern your activities. Several policies, governing the conduct of research, patents and copyrights, and the use of the Harvard name, are relevant even if you receive no external support and engage in no activities elsewhere. In addition, if you are engaged in any external activity — teaching, research, or consulting — you must comply with the University-wide policies set forth in the third document.
Other documents are relevant to broad segments of the community. If, for example, in any part of your teaching or research, you (i) host and work with externally-supported postdoctoral associates, or (ii) conduct interviews or other studies of human subjects, or (iii) conduct research sponsored by for-profit institutions, or (iv) experiment with animals, you should be sure to consult the policies that cover these areas.
In general, policies associated with research are overseen by standing committees of the Faculty, primarily the Committee on Research Policy [Chair: Alexander Schier, schier@fas.harvard.edu; Secretary: Pat Fitzgerald, pwf@fas.harvard.edu] and the Committee on Professional Conduct [Chair: Peter Ellison, pellison@fas.harvard.edu; Secretary: Gearóid Griffin, gearoid_griffin@harvard.edu].
The remainder of this foreword briefly summarizes some of these documents and provides additional information on where, and from whom, to seek further information.
The first document in this booklet, Principles Governing Research at Harvard, is very broad. Its italicized and numbered principles apply to all research conducted at Harvard. Paraphrased, these principles include the following:
The remainder of the first document (the preamble and the discussion of the numbered points) provides some of the reasoning behind this legislation.
The topics of the next three documents — conflicts of interest and commitment, and external activities — have been identified by the President and Fellows as requiring special attention. Faculty members must affirm at regular intervals that these documents have not escaped your attention.
The document Policies Relating to Research and Other Professional Activities Within and Outside the University, sets forth principles and policies that apply to all professional activity, no matter where and under whose auspices it is conducted. The first paragraph of this statement displays its sweeping scope:
With the acceptance of a full-time appointment in the Faculty of Arts and Sciences, an individual makes a commitment to the University that is understood to be full-time in the most inclusive sense. Every member is expected to accord the University his or her primary professional loyalty, and to arrange outside obligations, financial interests, and activities so as not to conflict with this overriding commitment to the University.
The statement gives examples of acceptable activities (Category A), activities whose acceptability must be discussed with the Dean or the Committee on Professional Conduct (Category B), and unacceptable activities (Category C). Note particularly the restrictions on private consulting arrangements and other extramural professional activities.
A second appendix to this document outlines additional rules that apply when Federal grants and contracts are involved. As mandated by the National Science Foundation and all Public Health Service agencies, these rules specify: (i) conditions under which financial disclosure is required; (ii) procedures for the review of disclosures, the resolution of conflicts, and the maintenance of records by a designated individual, committee, or office; (iii) enforcement mechanisms with sanctions; and (iv) procedures for notifying agencies when conflicts cannot be satisfactorily resolved.
The third document, Harvard University Policy on Individual Financial Conflicts of Interest for Persons Holding Faculty and Teaching Appointments, is the 2010 vote of the President and Fellows that establishes University-wide standards for addressing financial conflicts of interest. Individual schools are charged with ensuring that these standards (and any additional standards the schools may wish to implement) are acknowledged, publicized, and implemented.
In August of 2011 the NIH published new regulations for disclosure of significant financial interests, and University and FAS policies are being reviewed and modified as necessary to ensure compliance with required standards for investigators supported by that agency.
The fourth document, the Statement on Outside Activities of Holders of Academic Appointments, is also a University-wide policy. Part of this statement deals with conflicts of interest and commitment in research and consulting. Other parts address external educational activities. Although educational institutions collaborate closely to everyone's benefit, each institution expects its faculty to work with its students and to help it attract the best faculty and students. Please note that the restrictions on activities for other educational institutions are considerably tighter than those on activities that complement, but less directly parallel, teaching at Harvard. Issues relating to educational activities that rely on digital technology are also discussed.
The fifth document, Guidelines for Research Projects Undertaken in Cooperation with Industry, deals with some of the additional issues that can arise when research at the University is conducted in collaboration with, or sponsored by, a for-profit organization. The guidelines are intended to avoid impediments to the free and open exchange of knowledge, to preserve scholarly standards absent peer review, to assure that industrial sponsorship does not adversely affect graduate student education, and to avoid financial conflicts. The first five documents are closely linked and refer to one another.
The sixth document places conditions on research conducted at the University that makes use of materials and data with restricted access. The aim of these conditions is to assure that the materials researchers use in drawing conclusions are available so that disinterested investigators can assess the results and conduct further studies. The credibility and scholarly value of research are diminished when access to biological materials, or to privately held letters and papers, is restricted to chosen researchers.
The seventh document, Procedures for Responding to Allegations of Misconduct in Research, describes the procedures the Faculty has developed for responding, with due respect for both the "whistle-blower" and the accused, to any allegation of misconduct. All researchers have scholarly obligations to their colleagues and coworkers. Principal investigators with external funding also have legal and ethical obligations to sponsors and to the University in its administrative oversight role.3 As in the case of conflicts of interest, Federal agencies have adopted their own rules about what constitutes misconduct in research, and what standard of evidence applies. Researchers sponsored by these agencies are subject to both University and agency strictures.
The next two documents set forth policies on the use of human subjects in research [Committee on the Use of Human Subjects office: cuhs@fas.harvard.edu, 617-496-CUHS] and the use of living animals or animal materials in research and teaching [IACUC office: iacuc@fas.harvard.edu]. Separate standing committees administer these policies. Each oversees activities that are subject to city, state, and federal statute. In addition, a University-wide committee, appointed by the Provost, reviews all research involving the derivation or use of human embryonic stem cells [Embryonic Stem Cell Research Oversight Committee, http://escro.harvard.edu].
The protection of the community's health, safety, and environment has always been a foremost concern of the University. To assure that we all understand what we must do to safeguard ourselves and our neighbors, a detailed plan has been developed. This Environment and Safety Plan, the next document in the booklet, includes and subsumes the specific policies adopted for handling hazardous biological agents, now overseen by a University-wide Committee on Microbiological Safety [http://www.hms.harvard.edu/orsp/coms/].
The transport of hazardous materials can pose serious dangers to the public. Extensive regulations have been enacted to guard against those dangers. Individuals planning to transport materials or equipment that could conceivably pose a safety hazard may acquaint themselves with these regulations at http://www.uos.harvard.edu/ehs/environmental/dangerous_goods_shipping.shtml.
The next document, Stipulations Regarding Research Appointments Within the Faculty and Affiliated Institutions, establishes appointment procedures and employment conditions for the six categories of non-faculty research positions: Postdoctoral Fellow, Research Associate, Visiting Scholar, Senior Research Fellow, Associate, and Research Fellow. Of these categories only Research Fellows and Senior Research Fellows are routinely eligible for Principal Investigator status, the right to direct sponsored research in the Faculty of Arts and Sciences. Traditionally, this privilege has been severely restricted. Others not eligible to serve as Principal Investigator may, in some cases, petition the appropriate Divisional Dean to allow an exception to the PI status policy.
Together with the University-wide policies on patents and copyrights, you will find the University-wide policy on the use of the Harvard name and the ownership of software policy of the Faculty of Arts and Sciences.
The most current versions of all documents in this booklet, and other relevant publications, are maintained on the World Wide Web at http://www.fas.harvard.edu/~research.
Comments, questions and suggestions should be sent to the Chair of the Committee on Research Policy (Alexander Schier, schier@fas.harvard.edu).
[Revised December 2011]
1. Researchers are also strongly encouraged to disclose sources of prior substantial research support, especially when many in their audience might consider these sources relevant.
2. Notwithstanding their independence, investigators who cite their University addresses but are not regular members of the Faculty normally should indicate the nature of their affiliation, e.g., Associate of the ... Museum.
3. Experience has underscored the critical importance of maintaining and assuring that students and associates keep careful laboratory records.