Memo 7/10: Biorisk Manangement Policy
The University’s updated biological health and safety policy, S5/09 Biorisk Management, has now been posted on the Safety Office website. Please note that this policy will not be distributed to departments as a hard copy as it is expected to require updating to reflect a number of ongoing changes in legislation. However, the main policy document is available to download as a pdf document from the website should it be required. Elements of the old policy (S1/95) that have not required updating will be added shortly.
This new policy establishes the University’s commitment to effective and comprehensive biorisk management (incorporating both biosafety and biosecurity), adopts a number of previously ad hoc and informal arrangements, and separates management procedures from laboratory biosafety issues. The latter, summarized in Appendix 2, form the basis of a biosafety manual for laboratory workers to refer to.
A meeting of BSOs will be held as soon as possible to explain fully this policy. In the interim, the main issues of note and the significant changes from the previous policy are at the following points in the main document:
3(c) In accordance with SACGM guidelines, all genetic modification of Arabidopsis thaliana, regardless of actual or perceived lack of hazard, must be assigned to Containment Level 2 as a minimum, as it is able to propagate and disseminate widely in the environment.
3(d) Identifies the levels of supervision, instruction, and training required for the different types of worker and requests that accurate training records for all individuals are maintained.
3(d)iii Requires that a department undertakes a formal check and verification of visitors from other institutions to prevent malign actions.
3(d)v Suggests that an annual statement of safety provisions is used as one means of identifying clearly that all necessary risk assessments have been undertaken and are up to date, and all training and supervisory arrangements have been identified.
3(g) Requires access to Containment Laboratories to be restricted to authorized personnel only. Containment Laboratories and authorized personnel are defined clearly. This point also identifies the requirement for a local policy on children entering biological departments. The requirement for suitable risk assessments for children entering laboratories or departments to work, or as visitors, is also addressed in University Policy Statement S1/13, ‘The Health and Safety of Young People and Children)’.
3(h) Introduces the concepts of maintaining the biosecurity of valuable biological materials and of pathogen accountability, and identifies the means of ensuring these.
3(i) Notes the requirement to inform the Safety Office of the acquisition of all micro-organisms into any University department or unit.
3(j)i Identifies a requirement to validate disinfectants used in situ in Containment Level 3 laboratories annually as a minimum.
3(j)ii Identifies a requirement for weekly monitoring of autoclave performance and the option of applying for derogation from the requirement to validate autoclaves used for making safe waste from Containment Level 1 or 2 laboratories on an annual basis.
3(l)ii Identifies a requirement for annual sealability testing of Containment Level 3 Laboratories and indicates the means of achieving this.
3(l)iii Describes “non-containment” facilities where some, or all, controls may be relaxed subject to approval by the Safety Office.
3(l)iv Describes the various approaches that may be taken to manage circulation spaces, offices, and write-up areas in proximity to Containment Laboratories.
3(l)vii Identifies an explicit requirement for laboratory furniture to be non-permeable.
3(l) ix Identifies a requirement for departments to provide storage for personal items so they are not taken into Containment Laboratories.
3.(l)x Identifies a requirement to make safe or otherwise account for work areas and biological material upon departure from a laboratory or department.
3(m)i Identifies a requirement to wear eye protection at all times when working in Containment Laboratories*. This requirement is based upon the failure of departments to manage risk assessments where eye protection is identified as a control measure, as has been requested repeatedly (see University Policy Statement S8/10 and Memos M20/07 and M6/08), and to reduce significantly the number of accidents and incidents involving eye splash or impact.
The inclusion of this measure has not been undertaken lightly and involved significant debate at many levels, but the number of incidents reported indicates that it is only through chance that no serious or long term injury or infection has occurred to date. The risk to workers of injury or infection is therefore considered to be too great to allow the existing situation to remain. Departments will be expected to enforce this requirement as a matter of priority by whatever means are the most appropriate.
The point also reinforces the requirement for laboratory coats to be worn at all times when working in Containment Laboratories as required in the COSHH and GMO Contained Use Regulations, and also to wear sensible enclosed footwear.
This point addresses the issue of write-up areas within laboratories and the wearing of personal protective equipment.
3(m)iii Reiterates that all new liquid nitrogen storage vessels must be of “vapour phase” type only. It also identifies the expected protocols for removal of pathogenic and non-pathogenic samples from liquid nitrogen storage.
3(m)iv Identifies the option of applying for derogation from the requirement to fumigate biological safety cabinets prior to maintenance where no pathogens are being used.
3(m)vi Stresses that needles must never be re-sheathed before disposal unless safe means of doing so for operational reasons have been introduced and approved. This information must be imparted to all laboratory workers.
* NB The Safety Office will provide funding for the purchase of appropriate eye protection in the first instance. Departments should make their own arrangements for obtaining eye protection and apply to the Safety Office for reimbursement by presentation of a copy of the paid invoice. However, purchases must be approved by the Safety Office in advance of ordering to ensure that appropriate items will be purchased. A number of quotes have been obtained and it should be possible to provide a range of acceptable models to suit all workers for about £5 per pair or less.
Departments must purchase prescription eye protection themselves where eye protection is required by risk assessment and safety over-spectacles are not appropriate for the activity.