Dual Use Research of Concern (DURC) Policy Overview

Cornell University must identify and report DURC research and proposals to Funding Agencies starting May 6, 2025.

For each research/proposal:

• If you are currently completing the compliance section of a sponsored project, answer “Y/N” to the question "Does your project involve infectious agents meeting the definition of a PPP or have the potential to generate a PEPP infectious agent?"  in the Cornell Research Administration Support System–Sponsored Projects (RASS-SP) system.
• In Federal proposal submissions, answer “Y/N” to the question whether “the proposed work is subject to the DURC policy.”

How Do I Know if My Research is Subject to DURC?

To determine if your research/proposal is subject to DURC:

1. Use the DURC Self-assessment tool.
2. Reach out to your DURC Research Coordinator. 

The DURC Research Coordinator and You

The DURC Research Coordinator will help you:

• Assess whether your research is subject to DURC
• Complete any necessary DURC documentation
• Prepare materials for the DURC Institutional Review Entity (DURC-IRE) review
• Submit required information to the Funding Agency

The DURC Research Coordinator will communicate updates as federal guidance becomes available. This webpage will reflect the latest information and requirements.

The following diagram shows an overview of the DURC process. Each step is explained in its own section below.

1. Scope Assessment—The Principal Investigator (PI) uses the Research Services DURC Self-assessment tool to determine if their proposal is in-scope for DURC and reaches out to the DURC Research Coordinator for guidance.
2. Funding Proposal Review—The Funding Agency assigns the proposal a merit score for funding, requests additional documentation, and requests a full DURC determination/assessment for DURC proposals.
3. DURC Assessment—The DURC Research Coordinator works with the DURC Institutional Review Entity (DURC-IRE) Committee for each funded DURC project. The Committee works with the Cornell team to assess whether the proposal is in-scope for DURC and, if so, creates various DURC documents.
4. Final Approval—The DURC-IRE Committee works with the PI to complete the DUC docs and submits the DURC docs to the Funding Agency. The Funding Agency completes their review and sends their final approval to the Cornell team.
5. Project Lifecycle—After the award is accepted, the PI starts their research. The DURC-IRE Committee works with the Cornell team to conduct training, have regular reviews, and send scheduled DURC reports to the Funding Agency.

Glossary: Major Groups

The following describes the major groups who participate in the DURC process:

• Principal Investigator (PI)—The lead researcher responsible for conducting research and ensuring compliance with the DURC policy. The PI creates a proposal and participates in DURC assessments and scheduled DURC reviews.
• DURC Research Coordinator—The person responsible for shepherding PIs through the DURC process and creating a DURC-IRE Committee for each funded proposal.
• Submitter—The person or group submitting the proposal, DURC status, DURC docs, and DURC scheduled reports to the Funding Agency. The Submitter can be part of the Office of Sponsored Projects (OSP) (also known as the Authorized Organization Representative (AOR)), or the Institutional Contact for DURC (ICDUR).
• Cornell DURC Team—A group created for each proposal, consisting of the PI and the DURC Research Coordinator, assisted by the Submitter.
• DURC-IRE Committee—A committee consisting of a committee chair and a rotating staff of relevant faculty and professionals that reviews each funded proposal and determines if it is in-scope for DURC. For DURC proposals, the Committee works with the Cornell team to create DURC docs, conduct DURC reviews, and send scheduled DURC reports to the Funding Agency.
• Funding Agency—The Federal Agency who assesses a proposal for funding and gives final approval of DURC proposals. The Funding Agency receives scheduled DURC reports from the DURC-IRE Committee.

During Scope Assessment, the Principal Investigator (PI) uses the DURC Self-assessment tool to determine if their proposal is in-scope for DURC and sends the DURC status (Y/N) to the Funding Agency through the Submitter. If the proposal is subject to DURC, the PI reaches out to the DURC Research Coordinator for guidance.

The following diagram shows an overview of Scope Assessment:

• 1A. PI Self-Assessment—The Principal Investigator (PI) uses the DURC Self-assessment tool to determine if their research is in-scope for DURC.
• 1B. Send DURC Status to Submitter— The PI completes and submits the proposal along with its DURC status to their Grant and Contact Officer (GCO).
• 1C. Consult Coordinator—If the DURC status is yes, the PI consults with the DURC Research Coordinator about further analysis and next steps.
• 1D. Submit DURC Status—The Submitter (in this case, the GCO in the Office of Sponsored Projects (OSP)) sends the proposal’s DURC status (Y/N) to the Funding Agency.

DURC Next Steps

If the DURC Self-assessment tool implies your research is subject to DURC:

1. If you are currently completing the compliance section of a sponsored project, answer “Y” to the question "Does your project involve infectious agents meeting the definition of a PPP or have the potential to generate a PEPP infectious agent?" in the Cornell Research Administration Support System–Sponsored Projects (RASS-SP) system.
2. In Federal proposal submissions, answer “Y” to the question whether “the proposed work is subject to the DURC policy.”
3. Contact your DURC Research Coordinator to discuss next steps.
4. Be prepared to work with the DURC Research Coordinator to put together necessary documents for the DURC-IRE review.
5. Do not proceed with your research until you receive guidance from your DURC-IRE Committee and, if necessary, the relevant Funding Agency.

If Your Research Changes . . . 

Contact the DURC Research Coordinator immediately if your current or planned research changes, particularly if changes:

• Involve new agents/toxins
• Alter potential experimental outcomes
• Modify experimental approaches
• Modify agents or methods
• Change risk levels
• Change risk mitigation strategies.

During the Funding Proposal Review, the Funding Agency assigns the proposal a merit score for funding, informs the Cornell team of potential funding, and requests a full DURC determination/assessment for DURC proposals.

The following diagram shows an overview of Funding Proposal Review:

• 2A. Score Proposal on Merit—The Funding Agency assigns the proposal a merit score and determines if the proposal is fundable.
• 2B. Inform Cornell Team—If the proposal is fundable, the Funding Agency notifies the Cornell team. If the proposal is subject to DURC, the Funding Agency requests a formal DURC assessment.
• 2c. Prepare for Funding—If the proposal is fundable, the Cornell team prepares for funding by gathering information for their next steps (e.g., Just-in-Time responses, compliance approvals, award agreement review, etc.).

If a proposal is funded and subject to DURC, the Funding Agency requests a formal DURC assessment. The DURC Research Coordinator forms the DURC Institutional Review Entity (DURC-IRE) Committee, which works with the Cornell team to assess whether the proposal is in-scope for DURC and, if so, creates various DURC documents.

The following diagram shows an overview of DURC Assessment:

• 3A. Form DURC-IRE Committee—If the proposal is likely to be funded, the DURC Research Coordinator forms the DURC Institutional Review Entity (DURC-IRE) Committee, consisting of a committee chair and ad-hoc faculty who are experts in the field.
• 3B. Assess DURC Eligibility—The DURC-IRE Committee works with the Cornell team to assess whether the proposal is subject to DURC. The DURC assessment is determined and the DURC status is sent to the Submitter.
• 3C. Assess Risks—If the proposal is subject to DURC, the Committee works with the Cornell team to assess and document potential risks associated with the research, including biosafety and dual use concerns; risks are recorded in a template.
• 3D. Assess Risk-Benefits— If the proposal is subject to DURC, the Committee works with the Cornell team to assess and document risk-benefits, including a communication plan with publication and presentation considerations; risk-benefits are recorded in a template.
• 3E. Review and Approve—The DURC-IRE Committee reviews and approves the final DURC status (Y/N) and any DURC docs (the DURC assessment, Risks, and Risk-Benefits); they are ready to be sent to the Funding Agency through the Submitter.

DURC-IRE Committee

The DURC-IRE Committee consists of an IRE Committee chair and ad-hoc faculty who are experts in the PI’s field. 

The Committee may consist of:

• IRE Committee Chair (permanent member)
• Submitter (Institutional Contact for Dual Use Research (ICDUR)) (permanent member)
• Scientific Experts
• Research Data Security Experts
• Biosafety Experts
• Grant/Contract Experts
• IT Data Security Experts
• Communications Experts
• Institutional Biosafety Committee (IBC) Experts
• Institutional Animal Care and Use Committee (IACUC) Experts.

Note: If you have questions or concerns, contact your DURC Research Coordinator.

The DURC-IRE Committee works with the PI to complete the DURC docs and submits the DURC docs to the Funding Agency. The Funding Agency completes their review and sends their final approval to the Cornell team within 90 days.

The following diagram shows an overview of Final Approval:

• 4A. Submit DURC Status, DURC Docs— The DURC-IRE Committee sends the DURC status and DURC docs (DURC assessment, Risks, and Risk-Benefits) to the Submitter.
• 4B. Submit Final DURC Docs—The Submitter sends the final DURC docs to the Funding Agency.
• 4C. Send Final Approval—The Funding Agency conducts a final DURC assessment and sends the final proposal approval to the Cornell team within 90 days.