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Comment Letter

COGR, ABSA, and ASM request clarification on DURC/PEPP Policy March 25, 2025

Representatives of the American Society for Microbiology, the Association for Biosafety and Biosecurity International, and COGR are requesting a meeting with NIH...

Policy Perspective

COGR Submits Letter to EPA on NPRM Regarding Methylene Chloride; Regulation Under the Toxic Substances Control Act; Compliance Date Extensions

COGR, representing over 230 U.S. research institutions, submitted comments to the EPA regarding compliance date extensions for regulations on methylene chloride...

COGR Update

COGR’s September 2025 Update

The September 2025 COGR Update provides an overview of recent federal developments affecting U.S. research institutions, including proposed regulatory changes,…

Resources

Comment Letter 07 Nov, 2025

COGR, ABSA, and ASM request clarification on DURC/PEPP Policy March 25, 2025

Representatives of the American Society for Microbiology, the Association for Biosafety and Biosecurity International, and COGR are requesting a meeting with NIH leadership to discuss the implementation of the U.S. Government Policy for Oversight of Dual Use Research of Concern and Pathogens…

COGR Update 26 Sep, 2025

COGR’s September 2025 Update

The September 2025 COGR Update provides an overview of recent federal developments affecting U.S. research institutions, including proposed regulatory changes, executive orders, litigation updates, and agency-specific policy shifts impacting research funding, compliance, security, and administration...

Policy Perspective 23 Jun, 2025

COGR Submits Letter to EPA on NPRM Regarding Methylene Chloride; Regulation Under the Toxic Substances Control Act; Compliance Date Extensions

COGR, representing over 230 U.S. research institutions, submitted comments to the EPA regarding compliance date extensions for regulations on methylene chloride under TSCA. While supporting the 18-month extension, COGR questions the legal foundation for the underlying regulations, noting that…

Policy Perspective 31 Mar, 2025

NIH’s Implementation of the U.S. Government Policy on Dual Use Research of Concern and Pathogens with Enhanced Pandemic Potential

The document outlines the implications and implementation procedures stemming from the newly issued NIH policy (NOT-OD-25-061) on oversight of Dual Use Research of Concern (DURC) and Pathogens with Enhanced Pandemic Potential (PEPP). Effective May 6, 2025, this policy consolidates and supersedes…

Policy Perspective 24 Mar, 2025

COGR Joins Community Letter to NIH Requesting a Meeting to Discuss the Future Implementation of U.S. Government Policy for Oversight of DURC and PEPP

The letter, dated March 24, 2025, is a formal communication addressed to Dr. Matthew Memoli, Acting Director of the National Institutes of Health (NIH), from the leadership of the American Society for Microbiology (ASM), the Association for Biosafety and Biosecurity International (ABSA), and the…

Matrices & Trackers 26 Feb, 2025

Assessment of Research That Requires Institutional Review

This document outlines the requirements for principal investigators (PIs) to assess and report whether their proposed research falls within two federally defined categories related to dual use research of concern and pathogens with enhanced pandemic potential, as part of a federal grant…

Matrices & Trackers 26 Feb, 2025

PI Self-Assessment Tool for Category 1 and Category 2 Research

The document outlines a Principal Investigator (PI) Self-Assessment Tool designed to evaluate whether a research project falls within Category 1 (Pandemic Potential Pathogens, PPP) or Category 2 (Potential Enhanced Pandemic Pathogens, PEPP). Through a series of structured questions, the tool guides…

Event Materials 06 Jun, 2024

Institutional Discussion on OSTP’s Recent Report on DURC – Implications & Implementation : June 2024 Meeting

The document provides an overview and institutional discussion on the recent U.S. government policy overhaul regarding Dual Use Research of Concern (DURC) and Pathogens with Enhanced Pandemic Potential (PEPP), as detailed in the May 2024 Office of Science and Technology Policy (OSTP) report. This…

Comment Letter 27 Mar, 2024

COGR Responds to APHIS Notice of Proposed Rulemaking on Agricultural Bioterrorism Protection Act of 2002; Biennial Review and Republication of the Select Agent and Toxin List

The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, submitted comments in response to the USDA’s Animal and Plant Health Inspection Service (APHIS) Notice of Proposed Rulemaking (NPRM) regarding the biennial review and…

Comment Letter 13 Oct, 2023

COGR Responds to RFI on Potential Changes to the Policies for Oversight of Dual Use Research of Concern (DURC) and the Potential Pandemic Pathogen Care and Oversight (P3CO) Policy Framework

The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and related institutions, submitted detailed comments to the Office of Science and Technology Policy (OSTP) regarding proposed changes to the oversight policies for Dual Use Research of Concern (DURC) and…

Comment Letter 06 Oct, 2023

COGR Responds to Proposed Amendments to the NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules (NIH Guidelines) (88 FR 54332)

The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, submitted comments to the National Institutes of Health (NIH) regarding proposed amendments to the NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid…

Archived 28 Sep, 2016

COGR Submits Comments on NIH Guidelines on Recombinant or Synthetic Nucleic Acid Molecules

COGR responded to the National Institutes of Health’s (NIH) request for public comments regarding proposed amendments to the NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. COGR expresses support for the NIH’s intention to optimize the benefit of the…

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