Close Proximity Research & Training

The safety of our research workforce, learners, and broader communities is our leading priority. Research and research training protocols must be optimized to provide the lowest risk for COVID-19 transmission feasible. This may require innovative approaches and enabling new, more flexible ways of conducting research.

The most effective way to reduce the risk of spreading COVID-19 is to minimize the amount of time people are within 6 feet of each other. However, some complex research procedures, involving multiple personnel, cannot physically be performed while maintaining six-foot social distancing.

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Training: If close proximity is required for training purposes, including for animal-related procedures that involve close proximity work due to training and would otherwise allow for social distancing if training was not occurring, refer to the Close Proximity for Research Training Guidance below and use the Close Proximity for Research Training form to request approval from the Office of Graduate and Postdoctoral Studies.

Research:  If close proximity work is required to conduct an experiment and it is not related to training a learner, refer to the Close Proximity Research Guidance below and use the Close Proximity Research form to request approval from the Medical School Office of Research.

Animals: If close proximity is required for animal procedures other than training, refer to the Animal Care and Use Program FAQs and use the ULAM/EHS form to request approval from ULAM.

Close Proximity for Research Training Guidance

We are committed to providing our learners a public health-informed, in-person learning experience that reflects our commitment to their health and safety. With an international reputation for educational and research excellence, learners are an essential and valued component of the research enterprise.

The safety of our learners, the research workforce, and our broader communities is our leading priority. Training and research protocols must be optimized to provide the lowest risk for COVID-19 transmission feasible, while providing the greatest benefit to the learner. This may require innovative approaches and enabling new, more flexible ways of training and learning.

Learners must review and comply with the U-M Research Re-engagement Guidelines and have completed the mandatory training module: COVID 19: Working Safely in U-M Research Areas.

Close Proximity for Training Exception

The most effective way to reduce the risk of spreading COVID-19 is to minimize the amount of time people are within 6 feet of each other.  While introducing a learner to some laboratory techniques and/or performing certain complex research procedures, physical distancing may prevent adequate training.

All alternatives measures to eliminate the need for close contact should be rigorously explored prior to seeking an exception to physical (social) distancing during research training. Measures include but are not limited to:

  • Using on-line training modules.
  • Recording videos of skill demonstration using mounted cameras or using live platforms (e.g., Zoom) with a webcam.
  • Remaining more than 6 feet apart and alternating positions near the sample or equipment, with frequent decontamination of surfaces and equipment.
  • Working side-by-side at least 6 feet apart performing the same procedure.
  • Introducing a temporary plexi-glass barrier(s) or partition(s) to supplement social distancing.
  • Rearrangement of laboratory instruments and/or equipment to better accommodate distancing.

Evidence suggests that Personal Protective Equipment (PPE) similar to that used in Biosafety Level 2 research minimizes the potential transmission of SARS-CoV-2, the strain of coronavirus that causes COVID-19.

Therefore, close proximity training procedures may be permissible under the following conditions:

  • Enhanced PPE (lab coat, gloves, and surgical face mask with the addition of a face shield) must be used when at least 6 feet of social distancing cannot be achieved. Surgical masks may be re-used but should be replaced if the mask becomes wet or visibly soiled. Face shields should be decontaminated after each use and stored in a clean area or discarded if not resusable
  • Use of this PPE regimen in lieu of 6-foot distancing is only permissible in situations where distancing is physically impossible; otherwise, social distancing expectations must be maintained. If, at any time during the procedure social distancing is possible, it must be practiced.
  • Use of separate high-touch tools, where practicable, to avoid sharing.
  • Measures to minimize the time within 6 feet must be employed.

To facilitate research training and ease the financial burden on laboratories accepting learners, the Medical School Office of Research is partnering with the Office of Graduate and Postdoctoral Studies to provide learners with reusable face shields.

Process for Close Proximity for Research Training Safety Plan Approval

To assess the requirement for a training exception, the Close Proximity for Research Training Form must be submitted to the Office of Graduate and Postdoctoral Studies for review and approval (CLICK HERE to view a sample of the completed form).

Each request will be reviewed as to whether alternatives to close proximity work are feasible, the benefit to the learner, and potential incremental risk for transmission. Justifications based on convenience or solely on room/equipment availability will not be accepted.

If approved, the Close Proximity for Training approval should be uploaded as an addendum to your laboratory Safety & Hygiene Plan. The Safety & Hygiene Plans are accessible to department and Medical School leadership as well as EHS and may be reviewed from time to time for compliance with current state and university COVID guidelines and as part of routine inspections.

Principal Investigator Attestation

The Principal Investigator assumes the responsibility to ensure that trainers and learners understand their responsibilities and that they comply with all the safety requirements of the Close Proximity for Training Exception outlined above and in the approval notification. The PI should confirm all parties are comfortable with the plan as proposed and describe the escalation process if, at any point, the trainer or learner has concerns about their safety.

As part of the application process, the PI will attest that:

  • I will discuss the guiding principles and requirements for proximity research training with all lab members.
  • Senior lab personnel who will be undertaking the training role and the learner(s) will comply with all enhanced PPE requirements to perform close proximity work and follow all cleaning/disinfection protocols that are appropriate for the procedure(s) and, if required, that have been approved by EHS.
  • Laboratory personnel will adhere to existing six-foot social distancing and maximum room density directives in place by the State of Michigan when not performing work approved under this Close Proximity Safety Plan.
  • Laboratory personnel have been made aware that lab safety issues, including personnel who are ill or not following safety protocols, may be reported via the U-M compliance hotline website, by calling 866-990-0111, or contacting EHS at 734-647-1143 or emailing EHS-Covid-19-Reporting@umich.edu. A learner may also escalate concerns to ogps.trainingsafety@umich.edu.

Close Proximity Research Guidance

Alternatives measures to eliminate the need for close contact should be rigorously explored prior to seeking an exception to social distancing during research procedures. Measures to consider include but are not limited to:

  • Remaining more than 6 feet apart and alternating positions near the sample or equipment, with frequent decontamination of surfaces and equipment.
  • Introducing a temporary plexi-glass barrier(s) or partition(s).
  • Rearrangement of laboratory instruments and/or equipment to better accommodate distancing.

Evidence suggests that enhanced Personal Protective Equipment (PPE) minimizes the potential transmission of SARS-CoV-2, the strain of coronavirus that causes COVID-19.

Therefore, close proximity research procedures may be permissible under the following conditions:

  • Enhanced PPE  (lab coat, gloves, and surgical face mask with the addition of a face shield) must be used when at least 6 feet of social distancing cannot be achieved. Surgical masks may be re-used but should be replaced if the mask becomes wet or visibly soiled. Face shields should be decontaminated after each use and stored in a clean area or discarded if not reusable
  • Use of this PPE regimen in lieu of 6-foot distancing is only permissible in situations where distancing is physically impossible; otherwise, social distancing expectations must be maintained. If, at any time during the procedure social distancing is possible, it must be practiced.
  • Use of separate high-touch tools, where practicable, to avoid sharing.
  • Measures to minimize the time within 6 feet must be employed.

Process for Approval for Close Proximity Research

To assess the requirement for an exception to the 6-foot social distancing directive, the Close Proximity Research Form must be submitted to the Medical School Office of Research for review and approval (CLICK HERE to view a sample of the completed form).

Each request will be reviewed as to whether alternatives to close proximity work are feasible and the potential incremental risk for COVID transmission. Justifications based on convenience or solely on room/equipment availability will not be accepted.

If approved, the Close Proximity Research approval should be uploaded as an addendum to your laboratory Safety & Hygiene Plan. The Safety & Hygiene Plans are accessible to department and Medical School leadership as well as EHS and may be reviewed from time to time for compliance with current state and university COVID guidelines and as part of routine inspections.

Principal Investigator Attestation

The Principal Investigator assumes the responsibility to ensure that all parties involved in close proximity research understand their responsibilities and that they comply with all the safety requirements of the Close Proximity Research Exception outlined above and in the approval notification. The PI should confirm all parties are comfortable with the plan as proposed and describe the escalation process if, at any point, personnel have concerns about their safety.

As part of the application process, the PI will attest that:

  • I have discussed the requirements for close proximity training with all lab members.
  • Laboratory personnel involved in the close proximity work will comply with all enhanced PPE requirements to perform close proximity work and follow all cleaning/disinfection protocols that are appropriate for the procedure(s) and, if required, that have been approved by EHS.
  • Laboratory personnel will adhere to existing six-foot social distancing and maximum room density directives in place by the University of Michigan when not performing work approved under this Close Proximity safety plan.
  • Laboratory personnel have been made aware that lab safety issues, including personnel who are ill or not following safety protocols, may be reported via the U-M compliance hotline website, by calling 866-990-0111, or contacting EHS at 734-647-1143 or emailing EHS-Covid-19-Reporting@umich.edu. Researchers may also escalate concerns to ummsresearch@umich.edu.

Close Proximity Research Involving Animal Procedures

If close proximity is required for animal procedures other than training, refer to the Animal Care and Use Program FAQs and use the ULAM/EHS form to request approval from ULAM.