Considerations and Processes for Remote Research
The shift of on-campus work to a remote posture may present export control risks, particularly if research work will be performed by faculty, staff or students who are located outside the United States. U.S. export control laws and regulations must be considered before you or your team conduct research outside the United States.
Most academic work – subject to the caveats detailed below – is considered fundamental research under these regulations, and therefore the results of that work can be freely shared and distributed anywhere in the world. Information that is public in nature or broadly available in academic classes is exempt from export controls. Information, whether embodied as software or technology, derived from research that itself is not subject to any dissemination restrictions is also exempt from export controls.
The following technologies, commodities, and academic activities are not exempt from export controls, and the Office of Trade Compliance will help you assess and manage your risk under the export control regulations.
Embargoed and Sanctioned Countries: Any research activities that are proposed to take place in the following countries and regions or by their citizens must be reviewed by the Office of Trade Compliance prior to engagement: Iran, Cuba, Syria, North Korea, Crimea, Donetsk, Luhansk Regions of the Ukraine, China, Russia and Venezuela.
Research Topics Relevant to U.S. National Security: The following topics carry elevated risk under the export controls regulations and require review prior to initiation:
- Research involving select agents, chemicals or other biologicals
- Specific military applications
- Space Research
- Nuclear Technology
- Artificial Intelligence
- Machine Learning
- Quantum Computing
- Additive Manufacturing and 3D Printing
- Position, Navigation and Timing (PNT) Technology
- Highly encrypted hardware or software
This list, which focuses on areas where Pitt has current research activities, is not comprehensive.
Physical Shipments (Exports): Any University employee with a computing ID that sends express mail or ground shipments must use the University’s ProShip system. This web-based system contains both export controls and hazardous shipping questions and will serve as the clearing house for all items sent to a foreign location.
Hand Carried Items when Traveling: Items taken on a plane, boat or other form of transportation to another country are considered exports, and in many cases need to be declared to U.S. Customs and Border Protection and in some cases also the Census Bureau. More information on this topic can be found on Pitt’s International Engagement web page under Outgoing Transfers. Pitt employees planning to travel to a foreign location are also asked to follow the University’s current guidance on travel. This guidance also requires Pitt employees to register their travel through the University Center for International Studies.
Student Research Projects: Undergraduate class research projects typically utilize public and academic information and do not need to be reviewed for export controls unless they are taken by an individual located in one of the above named embargoed or sanctioned countries. Graduate courses research projects more frequently use or create a technology or commodity that are not exempt from export controls and will require review from the Office of Trade Compliance if the topic is one of the listed research topics that carry elevated risk that may require an export controls license.
Export Control Reviews
The Office of Trade Compliance will need some detailed information from you to conduct an export controls review. Please complete the following form (PDF), which includes instructions and directions for submission.
The Office of Trade Compliance is available to answer any of your export control questions and may be contacted by email at Tradecompliance@pitt.edu.