When the Export Control Staff determines that some aspect of a research project is subject to export controls, UNL policy requires the implementation of a technology control plan (TCP). A TCP is a document that details procedures designed to eliminate or minimize the risk of unlicensed exports in labs and other research facilities engaged in export-controlled research. A TCP also documents all personnel authorized to participate in export-controlled activities and access export-controlled items and information.
The Export Control Staff will work with your research team and other UNL administrative units to develop an appropriate TCP if one is required. Keep in mind that a TCP is separate from other lab or research protocols and must be implemented in addition to them. This means that a project may need to have an IBC protocol, and IRB protocol, and a TCP in place, all at the same time.
UNL policy requires that a TCP be in place prior to commencing any controlled activities or receiving controlled information, regardless of the involvement of foreign persons in the research. All participants in a controlled research project must also complete training on export control compliance. This means that when Export Control Staff determine that your project is controlled, grant funds will not be released until all participants have completed the training course and an appropriate TCP is in place.