Regent Policy 2309: Policy Requiring Special Review/Approval Procedures Prior to University Submission of Research Proposals to Tobacco Industry Funders

Adopted September 20, 2007
Amended September 10, 2018*

1. The Regents exhort University researchers to:
   1. Consider carefully whether to accept research funding from the tobacco industry (and whether their research might be better served by seeking funding from alternate sources).
   2. Exercise the utmost care in assuring that their research (including research carried out with tobacco industry funding) adheres to the highest scientific and ethical standards. This includes being particularly vigilant about not allowing any funder to direct or control the outcome of the research or the dissemination of its results.
2. The Regents direct the Chancellor to establish a policy requiring that prior to the submission of any proposal to seek research funding from the tobacco industry, the research proposal must be reviewed by a scientific review committee drawn from the community of scholars designated by the Chancellor for this purpose, and must be approved by the Chancellor. Additionally, The Regents shall receive timely notice of such grants and a description of the research to be undertaken. Under the policy:
   1. The scientific review committee shall be charged with reviewing proposals intended for submission to tobacco industry funders, and with advising the relevant Chancellor regarding whether a proposed study uses sound methodology and appears designed to allow the researcher to reach objective and scientifically valid conclusions.
   2. The review committee shall be composed of at least three faculty members with expertise in areas of science relevant to the proposal being submitted. If a standing committee is established for this purpose, a provision shall be made allowing for consultation with experts in additional areas or from specific campuses, as needed, to appropriately evaluate a particular research proposal.
   3. For each proposal it reviews, the scientific review committee shall produce a written report including a recommendation as to whether the proposal should be approved for submission, and/or whether any changes should be made to the proposal prior to submission, along with the rationale for the committee's recommendation. The report should be sent to the researcher, the Chancellor, the President of the University, and The Regents and shall be publicly posted on the UCOP website.
   4. Chancellors shall be directed to take the advice of the review committee into account in deciding whether to approve submission of the proposal by the campus. Chancellors shall also be directed to take into account any advice issued by the campus conflict of interest committee, in cases where under existing policy requirements, the researcher has disclosed a financial interest in the research sponsor.
   5. The Chancellor shall issue his or her determination (i.e., whether the proposal is to be approved for submission, with or without changes) in writing, including a rationale for his or her determination, with a copy to be sent to the researcher, the President, and The Regents. A copy of the Chancellor's determination letter shall be publicly posted on the UCOP website.
3. The Regents directed the President to prepare and submit to The Regents an annual report summarizing the number of proposals submitted to the scientific review committee, the number approved, and the number funded, along with a description or abstract of each proposal. The reporting requirement was kept in place for at least five years, which allowed The Regents to review the type of research conducted by University researchers with funding from the tobacco industry. After five years, the President consulted with The Regents to evaluate whether the reporting requirement should be continued and in July 2014 the Regents eliminated the report.

*Technical Amendments made by the Secretary and Chief of Staff to the Regents per Policy 1000