IRE – DURC & PEPP

News from the NIH Office of Science Policy:

NIH Office of Science Policy announcement regarding the DURC/PEPP Policy which was set to take effect May 6, 2025.

Executive Order on Improving the Safety and Security of Biological Research

Questions can be sent to: SciencePolicy@od.nih.gov

Link to Subscribe to OSP News

 


 

USG Policy for Oversight of Dual Use Research of Concern (DURC) & Pathogens with Enhanced Pandemic Potential (PEPP)

Previous implementation date was set to take effective May 6, 2025. The Policy for Oversight of DURC & PEPP (herein referred to as DURC & PEPP Policy) will supersede previous DURC and P3CO Life Science Policies.

Implementation Guidance document contains agent specific details, examples of research within the scope of the policy, and tools to aid in compliance for all involved in life sciences research - PIs, institutions, IREs and federal funding agencies.

NIH issued a notice on January 10, 2025, announcing intentions to implement the DURC & PEPP Policy effective May 6, 2025. NIH stated that they would provide additional details and requirements, including applicable grant and cooperative agreement activity codes, specific implementation timelines, and information regarding implementation for other NIH funding mechanisms, in future Guide Notices. As of May 5, 2025 no additional guidance has been provided.

In the meantime, the UConn IRE is working to develop procedures to best assist PIs with the new requirements.

 

 

 

PI Responsibilities

Applicability: New Proposed & Ongoing Research

Complete

Initial Assessment

  1. Assess based on agents and experiments within the scope of the policy.
  2. Must complete by proposal stage for new awards, and as requested for ongoing projects
  3. Complete using Kuali Form:  PI Self-Assessment Tool 
  4. Forms automatically forwarded to PI and the IRE.
  5. If assessed as Category 1 or Category 2, notify FFA of potential DURC or PEPP at time of proposal!
Assessment Results

NOT DURC or PEPP

  1. Continuously monitor research for changes that could affect assessment.
  2. If changes occur where research becomes DURC or PEPP, STOP WORK IMMEDIATELY!
  3. Notify FFA and IRE as soon as possible.
  4. Work with IRE and FFA to complete applicable documentation (risk-benefit analysis and risk mitigation plan).
Assessment Results

may be DURC or PEPP

  1. Notify Sponsor that research may meet DURC or PEPP at time of proposal
  2. Notify IRE of Initial Assessment
  3. Collaborate with IRE on Risk-Benefit Assessment and Risk Mitigation Plan
  4. Submit required DURC or PEPP documents to Federal Funding Agency (FFA)
  5. FFA reviews and approves Risk Mitigation Plan prior to awarding
  6. ALL approvals must be in place PRIOR to initiation of research!
Image of the DURC & PEPP Assessment process from the PI perspective.

 


Institutional Review Entity (IRE)

  • IRE is an entity established by the institution to execute oversight responsibilities described in Section 5.2 of the Policy.
  • UConn's IRE was established as a subcommittee of the IBC in 2014, and granted authority to fulfill the responsibilities outlined in the current DURC Policy.
  • With the expansion in scope of research subject to the DURC & PEPP Policy, the IRE will begin holding regular meetings to review potential Category 1 and Category 2 experiments.

IRE will be in touch with labs that may be impacted.

We are here to help! See contact information below, and reach out with any questions.

      Name Title Phone Email
      Danielle Delage, CPBCA IBC Program Director 860.486.1838 danielle.delage@uconn.edu
      David Cavallaro, MS, RBP, CBSP Biosafety Officer 860.486.3180 david.cavallaro@uconn.edu

       


       

      Framework for Nucleic Acid Synthesis Screening

       

      Policy effects the purchase of oligonucleotides and benchtop synthesis equipment. Federally funded PIs must purchase applicable materials from suppliers who screen orders for sequences of concern (SOCs).  SOCs are unique to specific pathogens.  Applicable materials must be purchased from Providers or Manufacturers that publicly state adherence to the Policy (on website or provide documentation). Labs may be contacted more frequently from vendors in the process of verifying legitimacy; additional documentation may be requested. How granting agencies will monitor adherence to this policy is unclear.

      Links below contain additional resources such as fact sheets, templates, and FAQs.

       

      Resources

      Additional resources and summaries on the new policy can be found below.

       

      NEW! PI Self-Assessment Tool

      PIs must complete initial assessments when research involves modifying pathogens or toxins.

      PIs will answer questions in the form to determine if the project may meet the scope of DURC or PEPP oversight requirements. Must be completed at the time of proposal for new research, so the IPR Form can be completed accurately. For ongoing research, assessments can be completed as requested, or any time you would like to assess the work in the lab!

      Contact ibc@uconn.edu if you need assistance! We are happy to schedule a time to meet remotely and walk through the form with you.

       

      Agents & Toxins

      Loader Loading...
      EAD Logo Taking too long?

      Reload Reload document
      | Open Open in new tab

      Download [731.89 KB]

       

      Assessment Workflow - DRAFT

       

      Image of the DURC & PEPP Assessment process from the PI perspective.

       

      Fact Sheet - DURC & PEPP Policy

      Loader Loading...
      EAD Logo Taking too long?

      Reload Reload document
      | Open Open in new tab

      Download [92.54 KB]

      COMING SOON!

      UConn Policy on DURC & PEPP

      Risk-Benefit Assessment Template

      Risk Mitigation Plan Template

      FAQs

      Frequently Asked Questions (FAQs)

      My lab does not receive federal funding, but RG2 pathogens are modified to enhance virulence and transmissibility. Do I need to comply with this policy?

      • DURC & PEPP Policy is applicable to non-federally funded research at institutions that receive federal funding, via term and condition awards. Since UConn is sponsored by federal funding agencies, your work should be assessed by the IRE.

      Who is responsible to determine if research is subject to the DURC & PEPP Policy?

      • PIs assess research initially, to identify covered research. PI assessments are reported to the sponsor and if the PI believes the project meets Category 1 or Category 2, the IRE must be notified as well.
      • UConn IRE will provide a Self Assessment Tool to aid PIs in conducting this assessment.

      I assessed my proposed research and my determination was that our new project may be subject to Category 2 oversight. What do I do now?

      • Contact the IRE and your sponsor. Do not begin work on any new experiments. The IRE must conduct an assessment of the PI's determination, which will result in one of the following workflows.
      • IRE Determination = Not Subject to Policy: The institution will notify the sponsor and the PI. Work can be initiated according to DURC & PEPP; however, other regulations may apply (e.g. NIH Guidelines). Contact the IBC to ensure the lab has all approvals necessary.
      • IRE Determination is Category 1 or 2 = Subject to Policy: Ensure sponsor is notified, and work with IRE to draft risk benefit analysis, and risk mitigation plans. Sponsor must conduct thorough review.

      Additional FAQs - S3: Science Safety Security, ASPR

      Current Life Science Policies – DURC and P3CO, expiring May 6, 2025

      Current Federal Policies on Life Sciences Research - Expiring May 6, 2025

      USG Policy for Institutional Oversight of Life Sciences Dual Use Research of Concern (DURC)

      Life sciences research is essential to the scientific advances that underpin improvements in public health and safety, agriculture (including crops and other plants and animals) the environment, materiel, and national security. Despite its value and benefits, certain types of research conducted for legitimate purposes can be utilized for both benevolent and harmful purposes. Such research is called “dual use research". The current policy defines DURC as a subset of dual use research defined as life sciences research that, based on current understanding, can be reasonably anticipated to provide knowledge, information, products, or technologies that could be directly misapplied to pose a significant threat with broad potential consequences to public health and safety, agricultural crops and other plants, animals, the environment, materiel, or national security.

      The 2014 DURC Policy will expire effective May 6, 2025; and will be replaced with the USG Policy on Oversight of DURC and PEPP described at the top of this page.

      Potential Pandemic Pathogen Care and Oversight (P3CO)

      Research involving biological agents and toxins is essential to the scientific advances that improve national and global health and safety. Such research does not come without potential biosafety and biosecurity risks. Work with pathogens and toxins must be carefully considered. Appropriate risk mitigation strategies must be implemented to protect personnel and public health and safety.

      Current regulations, policies, and guidelines regarding oversight for such work are as follows:

      1. 2012 Federal DURC Policy
      2. 2014 Institutional DURC Policy
      3. 2017 OSTP Potential Pandemic Pathogen Care and Oversight (P3CO)
      4. 2017 HHS P3CO Framework