Reactivating On-Site Research Operations at MSU During COVID-19: Preparing the Next Stages
Last Updated: 5/1/2020
I. External Policy Framework and the MSU Research Status Quo
For several weeks, normal research and creative activities on-site at MSU in East Lansing and at other University sites across the state have been substantially reduced or constrained by executive orders  by the governor and the Federal guidance  from the Cybersecurity & Infrastructure Security Agency (CISA) referenced in those executive orders, requirements promulgated at the county level by public health authorities , and MSU’s own policy decisions. 
Through the creativity and commitment of MSU faculty members, as well as their research colleagues and students, a substantial fraction of MSU research activity has continued in homes. In many areas of research and creative activity, such “at home” endeavor has advanced scholarship generally, by producing and disseminating results. It has also sought further funding for the University, helped students maintain career momentum, and addressed the continuous effort and performance timeliness expectations of government and other research funders. MSU is deeply grateful for those efforts, but is also cognizant that certain types of research cannot be conducted under current conditions and have therefore suffered serious interruptions. MSU is also very grateful for planning efforts for the reactivation of on-site research that have been undertaken already by a number of campus units, and anticipates those efforts will prove consistent and mutually supporting with the processes set forth herein.
Minimal basic operations of critical infrastructure (as defined by CISA guidance and permitted by the governor’s executive orders) for some other research activities has continued in several campus buildings and MSU sites across Michigan, as administratively approved within MSU.  Collectively, such legitimate, continued on-site research operations are termed the “May 1 Baseline” herein. Absent a major change in the external policy framework, the May 1 Baseline activities are expected to continue, subject to and in compliance with applicable health and safety mandates. The balance of this document discusses principles and baseline standards for the staged resumption at MSU sites of research activities outside of the May 1 Baseline.
 See: https://www.cisa.gov/sites/default/files/publications/CISA-Guidance-on-Essential-Critical-Infrastructure-Workers-1-20-508c.pdf . The governor specifically references the first (March 19th) version of CISA guidance.
 See, for example, the travel strictures at https://msu.edu/coronavirus/travel-advisories/ .
 See: https://vp.research.msu.edu/coronavirus .
II. Organization of Planning for the Research Reactivation on Campus
Planning for reactivation of MSU on-site research activity will exist in three layers:
- In light of evolving external constraints and general MSU policy decisions, Research & Innovation has established and will continuously update these University-level general principles for on-site research reactivation, thereby establishing institution-wide baseline expectations for staging;
- Colleges, or (by delegation) units within colleges, will develop their own College Staging Plans for review and approval in Research & Innovation; and
- Individual faculty investigators will develop a group Laboratory Plan for a Safe Return, consistent with the MSU general principles for on-site research reactivation and the applicable College Staging Plan.
Note: individual laboratories, departments, and colleges can impose stricter measures than the general guidelines we provide here.
III. General Principles and Baseline Expectations for MSU Research On-site Reactivation
The following general principles are subject to change in light of evolving external constraints. Based upon applicable constraints now in force, the following principles apply:
- MSU planning must comply with the evolving Federal, State, and local policy framework summarized above.
- MSU planning will be implemented so that public health conditions can be maintained. Foremost in the planning is the safety of the workforce and everyone associated with its return, including members of surrounding communities.
- A required contingency component of MSU plans will be reversibility, in case of a recurrence of local pandemic severity forces another contraction of research activity.
- MSU plans will be developed and implemented so that the infrastructure can support the reactivation of activity. Many laboratories and some entire buildings have been idle for over a month, and they must be prepared for occupancy.
- MSU planning will be as transparent as possible, to permit individual faculty to make plans that conserve their time and effort.
- Administrative review of plans will seek to ensure effectiveness and compliance in health and safety, at all levels: college/unit, building, and research group.
- Administrative appeals will be heard when requested, to ensure faculty are treated appropriately in light of the specific needs and risks of their research or creative activity.
- Research work that can be conducted at a satisfactory standard (including health and safety) at home must continue to occur at home, while public health orders governing individual activity remain in effect.
- Students may not be compelled to conduct research activities on campus as a condition of assistantship or postdoctoral research associate support, while public health orders governing individual activity remain in effect.
- All individuals should seriously consider whether they (or their family members residing with them) fall in a “high risk” category. If so, they are strongly encouraged to engage in research and other scholarly work at home while public health orders governing individual activity remain in effect.
IV. Requirements for College/Unit Staging Plans
In order to maximize rational “fit” between staging plans and circumstances within disciplines, staging plans will be initially developed by each college, for subsequent review in Research & Innovation and approval by the Senior Vice President for Research & Innovation or designee.
- In staging plans, attention must be paid to personal safety in under-populated buildings, parking ramps, lots, etc., in addition to in labs, shops, studios, offices, and other scholarly spaces. The default expectation is that individuals will not work alone in a lab, shop, studio, or an entire building, absent a case-specific determination to the contrary for cause, made in writing by the unit administrator.
- Where relevant, staging plans must acknowledge that animal studies will be limited to work that can be done with animals presently housed, or that could be bred in house to meet the research objectives. [Additional comments on lab animals may be found in Section VIII, below.]
- Where relevant, staging plans must acknowledge that there will be no changes in the present policy for human subject research.
- Staging plans must acknowledge the responsibility of every individual covered to comply with all applicable COVID-19 orders and policies, including state executive orders, county health commission orders, MSU institutional policies, and MSU Environmental Health & Safety policies. [For example, daily provision of electronic or paper personal health screening information will continue to be mandatory for anyone coming to campus, until further notice. Staging plans must reflect this requirement explicitly.]
- While remaining compliant with applicable orders and policies, as well as the general principles enumerated above, staging plans must set forth a rationally defensible, well considered balance between (i) a gradual (as opposed to universal and sudden) reactivation of MSU on-site research and (ii) the essential protection of health and safety for research participants, their families, and their communities. It is implausible that the entire MSU on-site research endeavor will be able to re-activate simultaneously, and College Staging Plans should reflect that reality.
- Staging plans may anticipate that wildlife research will be able to be conducted under physical distancing standards and applicable travel limitations.
- Staging plans must include provisions for periodic compliance monitoring and reporting in every building at every covered site.
- Staging plans calling for the reopening of entire buildings, or of laboratory facilities which have been closed, must include arrangements for IPF and EHS to conduct infrastructure assessment (including fume hoods, biosafety cabinets, autoclaves, emergency showers, eye wash stations, and engineering controls) and any needed pre-conditioning (e.g., water flushes or hood maintenance.)
- A staging plan applicable to a given building must be communicated to every individual possessing a building key, and must indicate the mechanism by which any subsequent plan changes will be communicated.
- A staging plan must indicate a mechanism by which any covered individual can obtain timely answers to questions regarding the contents or applicability of the college or unit plan.
- Prior to finalizing a staging plan and submitting it for review in Research & Innovation, the authoring college (or delegated unit) shall review it for the following:
- Avoidance of discriminatory impacts or assumptions;
- Reasonable protection of junior scholars whose careers may be endangered by long diversions from the normal course of research;
- Appropriate pursuit of any time-critical opportunities for research or creative activity;
- Protection of existing long-term projects and the fruits thereof;
- Explicit consideration of reversibility in case of severe recurrences of the pandemic,
- Explicit consideration of consistency with obligations to funders,
- Identification of the frequency and headcount of any off-campus travel implicit in the plan; and
- Avoidance of problems with safety, security, economic, regulatory, or other effects adverse to the University’s interests and obligations.
V. The Role of Faculty Principal Investigators in Planning for Their Groups
- In general, faculty principal investigators are the resident experts in their group’s activities, the risks they entail, and the best practices that mitigate them. Complementing that special expertise, the primary responsibility for safe conduct of a research project at MSU rests with the faculty principal investigator. Consequently, every research group will need to prepare its own “Laboratory Plan for a Safe Return” prior to re-occupancy, for review and approval by the authorized unit and/or college administrator(s). If a faculty member’s group is part of the May 1 Baseline but has not yet prepared a fundamentally similar plan, it must do so immediately.
- MSU Environmental Health & Safety is preparing templates oriented to different disciplinary areas, to assist faculty members in preparing “Laboratory Plans for a Safe Return.”
- With the exception of new requests for approval of research in critical infrastructure areas defined under CISA guidance, Laboratory Plans for Safe Return should not be approved by the college/unit until the College Staging Plan has been reviewed and approved in Research & Innovation. College-to-college differences in approver roles may occur, but every college will provide copies of all “Laboratory Plans for a Safe Return” that are approved within it to Research & Innovation. Although primary responsibility for regular compliance monitoring rests with the academic line, SVPRI staff will review plans received, and may continue to monitor them, for reasonableness and consistency with these evolving guidelines
- A unit decision to permit a PI’s group to resume on-campus research is distinguishable from the PI’s decision(s) to permit specific individuals in the group to be present on campus. The latter decisions should be written and demonstrably predicated upon the principle of avoiding unnecessary or otherwise unreasonable risks. To that end, no family members, undergraduate students not formally employed by the group, visitors, or visiting researchers are permitted in the buildings. Participation by undergraduate students formally employed by research groups is permissible when necessary to operations, if approved by the unit administrator.
- For those individual group members authorized to resume research on campus, there may be appropriate constraints on when any individual’s presence should occur. E.g., the use of shifts and of “platooning” a faculty PI’s research team members in small, non-overlapping groups can both help minimize quarantining that would result from a confirmed or suspected infection of a team member.
- “Laboratory Plans for a Safe Return” should contain:
- a clear indication whether or not the anticipated activity in the group will entail research or testing involving the live SARS-CoV-2 virus; this will require approved access to BSL-3 facilities.
- a derived maximum number of people who can work in the lab at any one time while maintaining social distancing, taking into account the square footage of the laboratory and using a minimum area of 6 foot radius to estimate space required – approximately 113 sq. ft. per person).
- an explanation of how the number of people who are proposed to work safely in the laboratory at any one time can be minimized generally, and always to a level below the derived maximum. In particular, all work that can safely and reasonably be done remotely must continue to be done remotely.
- acknowledgement that buildings must not be used for social gatherings or group meetings, that conference rooms and other group spaces will be off limits, and that phones, videoconferencing, or other electronic means must be used for group communication, until further notice.
- a discussion of how shifts and platooning measures will be employed while ensuring personnel are not required to work alone unsafely;
- acknowledgment that any individual’s on-campus presence should be limited to the time it takes to do the work envisioned in the plan;
- provisions for use of a sign-in and sign-out tool to determine who is (or was) in the laboratory at any one time. Such tools will preferably be personal and electronic, to avoid shared contact with multi-user rosters or writing utensils;
- a dynamic strategy for continuous physical (social) distancing while people are in the laboratory
- a training strategy (with mandatory participation) for disseminating the group’s Laboratory Plan for a Safe Return to all group members. Video training modules to assist in groups such training are being prepared by Environmental Health & Safety;
- proposed use of PPE that is not routinely expected for experimental procedures, including the mandatory use of cloth facing coverings in all public areas, as well as in enclosed spaces where such use is not obviated by the required use of more stringent PPE, such as N95 masks and/or face shields.
- the envisioned use of any shared equipment in the lab and who will use it, as well as the decontamination protocols to be employed before and after each use;
- the envisioned frequency and duration of use of any shared service facilities, including RTSF, the Max Rogers NMR Facility, animal facilities, etc.;
- where appropriate, a plan for coordinating activities with other research groups that occupy larger, multiple-PI laboratory space;
- group-specific confirmation of satisfactory assessments of fume hood, biosafety cabinet, autoclaves, emergency
- identification and scheduled remediation of any overdue preventive maintenance, waste disposal, safety re-training, coolant or lubrication renewal, software updates, etc., resulting from the recent hiatus in research operations on-site.
VI. Special Considerations for Break Areas, Kitchens, and Washrooms in Research Facilities
When research reactivation is to occur within a building, the unit with administrative responsibility for each break area, kitchen, or washroom will consult with IPF and EHS concerning the necessary sanitation schedules and practices. Off-campus facilities will consult with the Land Management Office or other managing unit. Relevant considerations in such cooperative planning include:
- the need to preserve the standard practice of excluding food from laboratories;
- the envisioned rise in headcount of those present, including the headcount distributions across days of the week and shifts;
- any COVID-19 activity (such as live virus research or testing) anticipated as part of the research expansion within the facility;
- the possible benefits of assigning non-overlapping group or sub-group schedules for use of break areas and kitchens, with interspersed sanitation servicing;
- the possible social distancing and sanitization benefits of limiting television use and either periodically re-sanitizing or impounding remote controls;
- appropriate occupancy limits for the size of break spaces, kitchens, and restrooms; and
- any special resources (funding, supplies, PPE, etc.) required for sanitization efforts beyond those utilized prior to the COVID-19 pandemic.
VII. Special Considerations for Research Facilities Distant from East Lansing
All provisions set forth above apply to statewide research sites owned or operated by MSU. In particular, although daily health self-screenings are mandatory by order in Ingham County, MSU has implemented them statewide at University and cooperator sites.
Off-campus research facilities and staff working off-campus may be subject to additional orders issued in their local health department jurisdictions. The University requires compliance with such orders.
Off-campus travel must be approved in advance, in accordance with University policies. The sharing of vehicles is prohibited until further notice.
VIII. Special Considerations for Research Involving Laboratory Animals
Resumption of breeding activities can start in early May so that animals can be available for June studies. Approved animal orders will be accepted for mid-to-late-May arrival.
New studies should be limited to time-sensitive work with specific goals, such as grant deadlines, publication deadlines, graduate student completions, etc. Large, staff intensive studies should be delayed.
Limited numbers of individuals will be permitted in animal facilities; times will be designated for animal care staff to care for animals and perform daily checks. Animal care staff will continue working as separate platoons, thereby reducing numbers of staff at any one time.
IX. Special Considerations for Research/Clinical Investigations Involving Human Subjects
For research involving human subjects, the restrictions in effect on May 1, 2020 are expected to continue until further notice.
- For research conducted in Michigan, all MSU human research activities conducted by MSU employees or agents that take place in Michigan, and that cannot be done remotely at home or place of residence with no inter-personal interaction with participants or others like research staff, must stop unless the project is (i) a clinical trial activity which, if discontinued, would negatively impact the patient’s care, or (ii) is urgently related to the COVID-19 pandemic. Please note that restrictions to human research in Michigan will continue to be evaluated based on any new Executive Orders and the restrictions may be modified as appropriate.
- For research conducted outside of Michigan, all in-person participant interactions in MSU human research conducted by MSU employees or agents, whether domestic or international, must pause unless there is the potential for direct therapeutic benefit to the participant (drug or device) and local requirements are followed.
For all human research studies, research procedures involving no direct in-person interactions with participants may continue (e.g. data analysis, online surveys, telephone interviews) in otherwise permissible venues, so long as State and local requirements are met.
For up to date information and details, please visit the HRPP COVID-19 webpage.
X. Assistance with Questions
Questions concerning this document, the preparation of College/Unit Staging Plans, or the preparation of a “Laboratory Plan for a Safe Return” may be forwarded to staff in the Office of the Senior Vice President for Research & Innovation at the following numbers and e-mails:
|Dr. Doug Buhler||(517) firstname.lastname@example.org|
|Dr. Doug Gage||(517) email@example.com|
|Dr. J. R. Haywood||(517) firstname.lastname@example.org|
|Dr. Paul M. Hunt||(517) 285-5646 (mobile)||email@example.com|