Recombinant DNA

No work with recombinant DNA can be done at Middlebury College without either review by the College’s Institutional Biosafety Committee or a statement, signed by the PI, certifying that the rDNA used in his or her research is exempt from IBC review. This statement must cite the section(s) of the NIH Guidelines that pertain to the research and must specify why the PI believes that the research is exempt from review.

Drug-Free Workplace Act of 1988

This federal certification requirement, designed to prevent individuals and institutions from receiving federal funding unless they have a drug-free workplace policy, applies to all federal grants and (with rare exceptions) to federal contracts for $25,000 or more. It applies to controlled substances as defined in 21 CFR 1308, but not to alcohol. Middlebury College must:

  • notify employees that controlled substances are prohibited in the workplace and specifies the penalties for infraction
  • establish a drug-free awareness program
  • inform employees on federally funded projects that they must follow the College’s policy and must notify the College, within five days, about any drug conviction that occurs at the workplace
  • notify the funding agency within ten days of learning of a drug conviction
  • punish convicted employees and require them to attend drug abuse assistance or rehab

Individuals must certify that they comply with the College’s policy.

Violations may result in termination of the grant or suspension or debarment of the institution or individual.

Delinquency on Federal Debt

This federal assurance/certification requirement, designed to prevent people and organizations from benefiting from federal programs while delinquent in repaying other federal programs, applies to all federal funding. For individuals, the assurance is usually provided by checking a box on a proposal application form. For institutional awards, the institution must certify that it is not delinquent.

If an individual or institution is found to be delinquent, funding could be withheld or reduced by the delinquent amount.

Debarment and Suspension

This federal certification requirement, designed to prevent fraudulent or improper use of government funds, applies to all grants and cooperative agreements and to most contracts. Applicants must certify that they, their principals, and their researchers:

  • aren’t debarred, suspended, ineligible for, or excluded from funding by any federal entity
  • haven’t been convicted of fraud or a criminal offense in connection with federal agreements within the past three years
  • haven’t been convicted of violating federal statutes within the past three years
  • haven’t been convicted of committing any form of theft or fraud within the past three years
  • haven’t been charged with any of these crimes by any government entity
  • haven’t had any government agreements terminated for cause or default within the past three years

Any subawardee or contractor who will get $25,000 or more must also so certify.

False certification could result in termination of the grant and debarment, suspension, or both.

Byrd Amendment: Lobbying

This federal certification requirement, designed to prevent lobbying to influence federal funding decisions, applies to all federal agreements. The PI must certify (by checking a box on the endorsement form) that nobody has lobbied on behalf of the proposal being submitted.

Failure to disclose lobbying activity results in the award being withheld; debarment or suspension may also result.