Transactions Requiring Prior Approvals
Reason for Policy
This policy provides guidelines to those departments, schools and/or units that are affected by the specific prior approval requirements in ARC associated with the acquisition of the commodities outlined in Appendix 1.
Primary Guidance to Which this Policy Responds
This policy responds to The University’s Purchasing Policy as well as specific Policies managed/enforced by the Institute of Comparative Medicine (ICM – Animals for Research) and the department of Environmental Health and Safety (EH&S) for commodities requiring prior approval in ARC.
Responsible University Offices and Officers
Responsible University Offices:
Procurement Services – Purchasing
Environmental Health & Safety (EH&S)
Institute of Comparative Medicine (ICM)
Responsible University Officers:
Vice President for Procurement Services
Vice President for Environmental Health & Safety
Director of Institute of Comparative Medicine
Who is Governed By This Policy
This policy applies to all personnel working for or on behalf of the University, who play a role in acquiring, using and/or paying for any of the commodities listed in Appendix 1.
Who Should Know This Policy
All University faculty and employees who make procurement decisions – including administrators in schools and departments who have primary responsibility for purchasing, and officers of instructions and research who make purchasing decisions – should be familiar with the requirements outlined in this policy.
Exclusions and Special Situations
All restricted commodities requiring prior approval must be processed through the Central Purchasing Office and are not covered by the Small Purchases policy. It remains the obligation of schools and departments to ensure that the appropriate category codes and chartfield account(s) are utilized when processing purchase requisitions in ARC. These codes are used by ARC to properly route these commodity transactions to the required set of approvers. The current listing of commodities and category codes governed by this policy are located on Appendix 1.
- Animals for Research: Pursuant to Federal regulations, the purchase of animals used in research must be made under the supervision and guidance of a qualified veterinarian. All requisitions for animals at the University must be issued and ordered by the Institute of Comparative Medicine (ICM). ICM prior approval in ARC is also required for any purchase of animal housing, related equipment and supplies. Questions regarding this policy should be addressed to the Director of the Institute of Comparative Medicine.
- Controlled Substances: The acquisition, use and disposal of controlled substances in New York State are strictly regulated by the New York State Department of Health (NYS DOH) Bureau of Narcotic Enforcement and the United States Department of Justice Drug Enforcement Administration (US DEA). These regulations are aimed at preventing diversion of controlled substances through a variety of administrative and physical controls. For the complete policy on the acquisition, use and disposal of controlled substances in research please go to: (http://www.ehs.columbia.edu/ControlledSubstances.html).
Purchase Orders for controlled substances must be accompanied by copies of the purchasers DEA Registration, New York State License, and RASCAL training certificate. The Rascal training certificate can be obtained by completing the Rascal module “Controlled Substance Use and Management in Research” (TC0502). Purchasing will not be able to process purchase orders without all accompanying documentation. Please review the Controlled Substances Policy for additional details.
Controlled substances purchased for clinical use by physicians to treat patients are regulated by the respective medical and DEA licenses issued to each individual physician and each physician is solely responsible for the proper administration, storage and disposal of controlled substances used in his/her practice.
- Capital Equipment: Capital equipment is defined under the University’s policies as Equipment/Systems valued at $5000 or more with a useful life of 2 years. Capital equipment must be acquired through the issuance of a Purchase Order and requires the use the proper ARC category code as well as account code as part of the respective account/chart-field designation. All Capital Equipment must receive approval in ARC from the Office of Capital Assets Accounting, a unit of the Office of the Controller, prior to the issuance of a purchase order. Once the Capital Equipment has been delivered and installed it must be tagged and entered into inventory. Prior to the payment of an invoice for Capital Equipment the item must be received in ARC.
- Radioactive Materials & Equipment: Requisitions from University departments, laboratories and offices for radioactive material and radiation generating equipment (e.g. Liquid Scintillation Counters, X RAYS & Lasers, etc.) must be approved in ARC by Environmental Health and Safety (EH&S) through the Radiation Safety Office prior to the issuance of a Purchase Order. Radioactive Materials (RAM) and radiation generating equipment must be ordered using a Purchase Order with the specific category code for RAM. RAM may only be shipped to preapproved shipping addresses for such categories. The P card may not be used for RAM orders. The Radiation Safety Committee of Columbia University supervises and oversees the use of RAM and radiation generating devices for the respective campuses including Barnard College. The Policy and Processes governing the use and handling of RAM and related equipment are administered by the Department of Environmental Health & Safety. Columbia’s ability to use RAM is governed by a campus and site specific license that is strictly monitored. For additional information regarding rules and regulations for the handling of RAM and related products go to: www.ehs.columbia.edu. The Radiation Safety Program administered by EH & S is also responsible for assisting the Columbia University community in the safe use of ionizing radiation producing equipment. This also includes X-Rays and Lasers. EH & S must grant approval in ARC for any equipment that has a ionizing radiation source. Please contact the Radiation Safety Office for specific guidance regarding the purchase, installation and safe use of any RAM and/or radiation generating equipment.
- Refrigerators & Freezers: FDNY Regulations prohibit the storage of flammable materials in non-rated refrigerators and/or freezers. Any purchase of a refrigerator or freezer in which flammable materials will be stored must obtain prior approval of EH&S in ARC. This approval is triggered through the use of the correct category code and is granted electronically in ARC by EH&S. Prior to obtaining this approval the department must submit a signed memorandum of understanding regarding the use of such refrigerator or freezer as well as the understanding that these refrigerators and freezers will not be used for food storage to avoid cross contamination. Newly purchased refrigerators and freezers are tagged by EH&S with the appropriate signage. For any guidance regarding this policy please contact a Research Safety Specialist at EH&S www.ehs.columbia.edu
- Ethyl Alcohol: The University may purchase and use Ethyl Alcohol (190 & 200 Proof) for research tax free under a specific Facilities maintained site license. This license is issued by the United States Department of the Treasury Bureau of Alcohol, Tobacco and Firearms. Departments are required to contact Facilities Management for any Ethyl and Pure Alcohol requirements for research.
- Executive Recruiting: All purchase requisitions relating to personnel recruitment activities that involve executive level searches requires the ARC approval of the Office of Management and Budgets (OMB). OMB must be notified in advance of any engagement of executive search services to ensure the appropriate budget has been established and approved.
- Photocopier/MFD: Departments that have identified the need to purchase or lease a photocopier/multi-functional device (MFD) are required to obtain a quote and process their request through University Print Services. Print Services is responsible for managing the UwPA for procurement and service of these devices. Additionally, this process ensures that the equipment provided through these vendor agreements includes required security functionality, specifically Hard Drive Data Wiping Software and Data Overwrite Security System. Any department that does not utilize a University-wide Purchasing Agreement supplier in the leasing or purchasing of a photocopier/multi-function device remains obligated to ensure that the leased or purchased equipment meets the requirements for Hard Drive Data Wiping Software and Data Overwrite Security System. For additional information regarding photocopier/MFD procurement, please see the related policy at [placeholder for policy link].
Hugh A. Horowitz, Executive Director Purchasing Operations (212) 854-4111