Brian

My experience and perspective is that you should be able charge
radiation waste disposal as a direct charge.  However, you will have to
explain it again, and again and again to funders, auditors, and every
other individual who has seen it as an indirect cost.  As a result, you
might as well confirm this approach with your contracting officer and/or
your auditor before you get too far out on a limb

It may be perfectly appropriate for a large medical research institution
to charge radiation waste disposal as an indirect cost, but for Eastern
Michigan University treating it as a direct cost may be the correct
approach. Neither is right or wrong.  The determination of whether it is
direct or indirect is dependent upon your cost structure, business
practices and other factors, and may not correspond to what other
institutions are doing.

Beyond allowable, reasonable and allocable, you have already given
yourself the justification to charge it as a direct cost:  "the
individual costs can easily be isolated and allocated to individual
grant projects."  As long as you have an auditable basis to charge a
particular grant, and it meets the allowable and reasonable tests, you
should be fine.

Greg

============================

Greg Doyle-Wandell
Director of Sponsored Programs
J. Craig Venter Institute
9704 Medical Center Drive, 4th Floor
Rockville, Maryland  20850

Phone: (240) 268-2755
Fax: (240) 268-4000

Email: xxxxxx@venterinstitute.org
Home Page: www.venterinstitute.org

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@HRINET.ORG] On
Behalf Of Brian Anderson
Sent: Friday, July 15, 2005 2:30 PM
To: xxxxxx@HRINET.ORG
Subject: [RESADM-L] Budgeting for Radiation Waste Disposal

An issue has come up at my institution regarding the budgetary treatment
of chemical waste disposal on grants, particularly radiation waste.

Since we don't use these materials very often in research on our campus,
the individual costs can easily be isolated and allocated to individual
grant projects (seems to meet the allowable, reasonable, allocable
test).  On the other hand, a faculty collaborator from another
institution informed one of our faculty that such costs if direct
charged would raise eyebrows because it is normally treated as a
component of institutional F&A cost.

Do you treat radiation waste disposal as F&A cost and include it in your
F&A rate proposal or do you treat it as a direct cost at your
institution?  I appreciate your comments.

------------------------
Brian Anderson, Director
Office of Research Development
Eastern Michigan University
Starkweather Hall, 2nd Floor
Ypsilanti, MI  48197
Office: (734) 487-3090
Fax: (734) 481-0650
Email: xxxxxx@emich.edu

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