BIOSAFETY
I. POLICY
It is the policy of the University of California,
San Diego (UCSD)
that all research and teaching involving biohazardous materials will be
conducted in a safe manner in order to protect the academic
community as well as the greater
community at large.
Please note that any possession of or work
with biohazardous materials that customarily requires Biosafety Level 4 (BSL4)
containment is prohibited
at UCSD.
This section outlines the policy and
procedures governing the safe use, propagation and/or release of infectious biological
agents, recombinant/synthetic DNA/RNA, and recombinant/synthetic organisms, including
plants, animals, and microbial agents.
Biohazard
materials covered in UC San Diego's Biosafety Program include:
·
Biological toxins
·
Infectious organisms that can cause disease in humans
or cause significant environmental or agricultural impact
·
Human or primate tissues, fluids, cells, or cell cultures
·
Animal tissues, fluids, cells, or cell cultures
·
Recombinant/Synthetic DNA in
vitro, in vivo, and in clinical trials
·
Transgenic plants or animals
·
Human gene transfer clinical trials
·
Releases of recombinant/synthetic DNA to the
environment
·
Animals known to be reservoirs of zoonotic diseases
·
Select Agents
- All
teaching and research activities involving biohazardous materials must be
authorized by the Institutional Biosafety Committee (IBC) before the work
commences. Persons contemplating work with any biohazardous material must
submit an
electronically
completed "Biohazard
Use Authorization" (BUA) to Environment, Health and
Safety (EH&S).
After
assessing the risks of the proposed work the IBC will establish the
practices, procedures, equipment and facilities that will be used during
the course of the proposed work and will grant authorization to conduct
the work.
- EH&S
personnel will periodically conduct announced and unannounced inspections
of the facilities to observe conditions and behaviors, talk to faculty
and staff, and review records to ensure that the conditions required for
the BUA are being
met.
- Many
people may work with or have potential for exposure to human blood,
tissues (or tissue culture), or other body fluids. This exposure may be
from clinical work, research, police work, first aid, life guarding,
coaching, child care, etc. Since any exposure to human blood has
potential to cause infection by a bloodborne pathogen (Hepatitis B virus,
HIV, etc.), a series of protective measures must be implemented by the
supervisor or department. These measures include a written "Bloodborne
Pathogens Exposure
Control Plan," a determination of "at risk" personnel,
procedures for evaluation of exposure incidents, Hepatitis B vaccination
acceptance
/ declination form,
training, and recordkeeping.
- All
University research involving recombinant/synthetic DNA molecules (r/sDNA)
shall be conducted in compliance with NIH
Guidelines for Research Involving Recombinant/Synthetic DNA Molecules (the NIH
Guidelines) regardless of the funding source.
II. APPROVALS
- The
following activities require approval of a Biohazard
Use Authorization (BUA) by the Institutional Biosafety
Committee (IBC).
- Research
activities that involve the use of recombinant/synthetic DNA technology
or products (see the NIH Guidelines, Section III and Appendices).
- Approval
is required before initiation of work, regardless of Risk Group
(biosafety level) or applicable section of the NIH Guidelines.
- The NIH
Guidelines provide further information on some required federal agency
approval of certain types of projects that involve recombinant/synthetic
DNA technology.
- Human
gene transfer/gene transfer trials must comply with NIH Guidelines, Appendix M.
- IBC Approval
must be obtained after the NIH Recombinant/Synthetic DNA Advisory
Committee has reviewed the project, but before any patients are
enrolled.
- PIs are required
to contact EH&S Biosafety for consultation and feedback prior to
submitting any experiments for NIH RAC review.
- Research
and other activities involving the use of microbial agents listed as
Risk Group 2 or 3 (see CDC/NIH BMBL,
fifth edition or later, the NIH Guidelines, or the UC San
Diego Biosafety website), or agents that are customarily
handled at Biosafety Level 2 or 3 regardless of Risk Group.
- Use must
be approved before transfer of agents to campus, medical center, or
affiliated laboratories and initiation of work.
- Importation
of human pathogenic microbial agents also requires Centers for Disease Control
approval.
- Importation
or interstate transfer of livestock or agricultural crop pathogenic
microbial agents also requires USDA-Animal and
Plant Health Inspection Service (APHIS) approval.
- The
activity shall be reviewed by the IBC prior to review by government
agencies requiring a permit for the activity.
- Research
activities involving the release of noxious or genetically engineered organisms,
including animals, plants, and microbial agents, into the environment.
- These
activities also require approval by the USDA.
- The
activity shall be reviewed by the IBC prior to review by the USDA or
any other government agency requiring a permit for the activity.
- Research
and other activities involving the possession or use of toxins (see
website for specifics) from the natural sources (including unicellular,
multicellular, plant, invertebrate and vertebrate sources).
- These
activities require IBC review and approval before toxins can be
transferred to the UC San Diego campus, medical center, or an
affiliated laboratory, and before work can be initiated.
- Work
with toxin-producing plant and animal species that does not involve
toxin extraction or isolation does not require IBC review.
- Work
with toxin-producing microbial agents requires IBC review and approval
regardless of whether toxins are intentionally being recovered.
- The
following activities are regulated under OSHA Bloodborne
Pathogen
and Medical
Waste Management statutes, and require approval of a BUA by
the IBC only as noted below.
- Activities
involving the use of human body fluids, human primary cell cultures,
established human cell lines, and unfixed human tissues.
- These
activities require the completion of a Bloodborne Pathogen Exposure Control Plan as part
of the Injury Illness Prevention Plan (IIPP).
- These
materials are always handled at Biosafety Level 2 or greater. Note that
any work requiring Biosafety Level 4 containment is prohibited here at
UCSD.
- Initial
training and annual refresher training in biological safety and
bloodborne pathogen exposure control are required.
- Activities
involving tissues or cells require approval of a BUA by the IBC.
- Activities
involving the use of nonhuman primate body fluids, nonhuman primate
primary cell cultures, established nonhuman primate cell lines, and
unfixed nonhuman primate tissues.
- Initial
training in biological safety and documentation is required as part of
the IIPP.
- These
materials are always handled at Biosafety Level 2 or greater. Note that
any work requiring Biosafety Level 4 Containment is prohibited here at
UCSD.
- Activities
involving tissues or cells require approval of a BUA by the IBC.
- Activities
that generate medical waste (i.e., human tissues, materials contaminated
with human tissues including body fluids, potential or known human
infectious agents, human pathogenic agents, or toxin-producing agents
including zoonotic agents).
- Training
on medical
waste disposal is required as part of the Laboratory Safety Principles
IIPP.
III. RESPONSIBILITY
- Chancellor
The Chancellor is responsible for ensuring that
research is conducted in full conformity with the provisions of the above
references. In order to fulfill this responsibility, the Chancellor shall:
- Appoint
and maintain an active Institutional Biosafety Committee (IBC).
- Appoint a
Biosafety Officer.
- On the
advice of the IBC, terminate, restrict, or deny any project or teaching
program not in compliance with this policy.
- Institutional
Biosafety Committee (IBC)
The IBC is advisory to the Chancellor through the
Vice Chancellor – Resource Management and Planning on all matters relating to
the safe use of biohazardous materials and organisms. It is the IBC’s
responsibility to establish, monitor, and enforce policies and procedures which
meet or exceed applicable norms or regulations for biohazardous materials
and/or recombinant/synthetic DNA, including gene transfer clinical trials. Any
use of biohazardous materials or recombinant/synthetic DNA must be reviewed and
approved by the IBC (or the Biological Safety Officer operating within
guidelines established by the IBC).
The IBC has the authority to impose disciplinary
measures in cases where there is willful or negligent violation of UCSD's
established biosafety practices and procedures. The sanctions are subject to
review and/or modification by the Chancellor. The IBC shall maintain diverse
membership representing the community and a variety of University interests.
Non-committee faculty or staff with a particular expertise will be asked to
advise the committee when the need arises.
The IBC shall maintain a record of committee
membership and procedures.
- Functions
of the IBC
- Establish
and implement policies that provide for the safe conduct of research
and teaching involving biohazardous materials.
- Ensure
appropriate training for the IBC Chair and members, Biosafety Officer,
Principal Investigators, and laboratory staff regarding laboratory
safety and implementation of the regulations and guidelines. The institution
is responsible for ensuring that the Principal Investigator has
sufficient training; however, this responsibility may be delegated to
the Institutional Biosafety Committee.
- Establish,
monitor, and enforce policy, practices, and procedures for all work
involving biohazardous materials at UCSD. The IBC shall ensure adopted
policies, practices, and procedures meet applicable regulatory
standards and guidelines.
- Review and
approve research proposals and other activities that involve biohazardous
materials.
- Review with
biohazardous materials conducted at or sponsored by UCSD for
compliance with adopted policies, regulations and guidelines
involving any of the following: (a) Recombinant/Synthetic DNA
technology, (b) Human gene transfer/gene therapy, (c) biohazardous
agents. This
review shall include an independent assessment of the containment
required, an assessment of the facilities and operational procedures,
as well as training and expertise of personnel involved in the
research. The IBC shall ensure that the Principal Investigator is
provided the results of the review and determination of approval in a
timely manner.
- Determine
the appropriate containment and handling (Biosafety) level (BSL) for
all projects reviewed in the BUA process.
- Recommend
modification, suspension, or termination of projects when it is in the
best interest of the health and safety of the campus and surrounding
community. Deny approval for any project that cannot be undertaken
safely at UC San Diego facilities. Refer prohibited experiments (see
the NIH Guidelines III.A) to the
NIH Recombinant/Synthetic DNA Advisory Committee for review.
- Develop
and implement emergency plans to cover accidental biohazardous
materials spills,
including r/sDNA,
and personnel contamination. The IBC will coordinate with institutional
officials and will cooperate with state and local public health
departments.
- Approve campus
biological safety-related practices (e.g., spill handling, laboratory
hygiene and conduct, standard practices, emergency response
procedures).
- The IBC
will report to
any appropriate regulatory agency any significant research-related
exposure,
illness
or release that
may be hazardous to the public health.
- Investigate
any significant violation of policies, practices, and procedures. The
IBC will also investigate any significant research-related accidents,
exposures, or illnesses. The IBC will determine and impose appropriate
disciplinary action should a thorough investigation reveal significant
violations of policy, practices, or procedure. The IBC will report its
findings and actions to appropriate UCSD institutional officials and to
the granting agencies as required.
- Review
and recommend policies and procedures for health surveillance of
individuals involved in programs using biohazardous materials. Determine
when employees who work with biohazardous materials should be offered
health surveillance. Determine the specific medical surveillance tests
which are appropriate for a given biohazardous materials risk. The
institution shall establish and maintain a health surveillance program
for at-risk personnel.
- Review
criteria for biohazardous materials containment facilities.
- Report
adverse events and violations of the NIH Guidelines to the NIH Office of
Biotechnology Activities unless it determines that the
principal investigator involved has already made such a report (e.g.,
adverse events in gene therapy trials).
- Research
Safety Manager -EH&S
- Acts as
Alternate Responsible Official or Responsible Official for the Select
Agent program as described in 42 CFR Section 73.
- UCSD
Biosafety Officer
The UCSD Biosafety Officer is appointed by the
University, is a member of the Environment, Health and Safety staff, and serves
as a member of the Institutional Biosafety Committee (IBC). The Biosafety
Officer's duties include, but are not limited to:
- Administers
the campus biological safety program (see also the NIH Guidelines, Section IV.B.3.c).
- Provides
services
to Faculty
and Staff
- Review
proposed biohazard research projects and recommends the biosafety
levels (BSL) for research projects to the IBC based on the Biosafety in
Microbiological and Biomedical Laboratories (BMBL)
and NIH r/sDNA Guidelines.
- Provide
technical advice to Principal Investigator s and to the
IBC regarding research
safety
procedures. This includes developing exposure control
plans for
the
safe handling, storage, and use of biohazardous materials.
- Advise
on the selection, installation, maintenance, and use of laboratory
equipment which provides or aids in containment of biohazardous
materials.
- In
consultation with faculty, staff, and the IBC, develop and implement
policies, procedures, and practices to reduce the risks of work with
biohazardous materials.
- Investigate
laboratory accidents, exposures, or releases
involving biohazardous materials research.
- Performs
periodic inspections to ensure that laboratory standards are rigorously
followed.
- Review government
agency permit applications that involve biohazardous materials
- Provide
guidance in
the development,
operations, and management of Biosafety Level 3 laboratories. Verifies
the safety of these laboratories before they become operational and
annually thereafter.
- Recommends
appropriate modifications of the Animal Care and Use Protocol to reduce
biohazard
risk.
- Ensures
continual accuracy of campus policies on the Biosafety website.
- Provides Training
Services
- Plan,
develop, and conduct training on biosafety issues, practices, and
procedures.
Provides training for safe handling practices involving biohazardous materials.
- Review
and approve laboratory-specific training plans for high-hazard
biohazardous materials research laboratories.
- Provides IBC
support
- Report
any significant problems, adverse events, violations
of the
NIH Guidelines and/or UCSD BioSafety policy violations,
or
any significant research-related accidents or illness
to the IBC (unless a report has already been filed by the Principal
Investigator).
- Implement
the decisions of the IBC.
- Review
BUA applications and prepares them for submission to the IBC.
- Provides
services to Facilities, Design and Construction, and Facilities
Maintenance
- Review
biosafety facility construction/remodeling plans and specifications.
Inspect construction/remodeling and authorize initiation of
biohazardous materials work following completion of construction.
- Provide
advice on biosafety facility design, ventilation needs, laboratory
security and
other supporting services.
- Manages
the select agent program when needed and serves as the Alternate
Responsible Official as defined in 42 CFR Section 73.
- Campus
Veterinarian
and or Vivarium Safety Officer
- At the
request of the IBC, the Campus Veterinarian shall assist in:
- Review
proposed biohazardous work in animals as part of the BUA process.
- Periodically
inspecting areas where infectious agents are used in animal
experiments.
- Training
and instructing animal caretakers in recognizing the potential risks
and utilizing special precautions when animals are exposed
to biohazard materials.
- Clearly
posting and labeling all such animal rooms.
- Overseeing
contamination control with regard to excreta, animal carcasses and
tissues, contaminated cages, cage bedding, and any other equipment or
object which has come in contact with animals or their products.
- Principal
Investigator
The Principal Investigator (PI) is responsible
for full compliance with the policies, practices, and procedures set forth in
the
policies on the UCSD
Biosafety websites.
.
This responsibility extends to all aspects of biosafety involving all
individuals who enter or work in his/her laboratory or other approved locations
to carry
out his/her research. Although the PI may choose to delegate aspects of the
biosafety program in his/her laboratory to other laboratory personnel or
faculty, this does not absolve the PI from the ultimate responsibility. The
PI remains accountable for all activities occurring in his/her lab.
- General
Responsibilities
As part of the general responsibilities, the PI shall:
- Every PI who is
new to the UCSD research community, and/or plans to begin work with
biological is required to attend a New PI Orientation. There are no
fixed schedules for these classes. They are arranged as needed. Call
extension 45366 for more information.
- Develop
and implement written laboratory-specific biosafety procedures (e.g. Exposure
Control Plans
and Standard Operating Procedures) consistent with the nature of
current and planned research activities and available laboratory
facilities. The PI shall ensure that all laboratory personnel,
including other faculty members, understand and comply with these
lab-specific biosafety procedures.
- Delay
commencement or modification of biohazardous materials work which
requires IBC approval prior to initiation (e.g. all
Risk Group
2 or greater agents until
that work or the proposed modification has been approved by the IBC and
meets all other requirements of the policies on the UCSD
Biosafety website.
- Should
any research project be required by the NIH Guidelines (see the policies
on the UCSD
website
appendices)
or by another agency to have prior agency approval before initiation,
these projects must be reviewed and approved by the IBC before they are
submitted to the agency.
- Ensure
that
all laboratory
personnel, maintenance personnel, and visitors who may be exposed to
any biohazard are informed in advance of their potential risk and of
the behavior required to minimize that risk. It is essential that
everyone who may have any potential exposure to biohazardous materials
enter and/or work in the laboratory under the principle of Informed
Consent. Refer to PPM 516-5.2, Hazard
Communication Program.
- If any
element of the
UCSD biosafety
policy
covered in your BUA is considered to be unachievable, the UCSD
Biosafety Officer should be notified immediately. Written notification must be
sent to the Biosafety Officer within five working days of the
determination.
- Ensure
that all maintenance work in, on, or around contaminated equipment is
conducted only after that equipment is thoroughly decontaminated by the
laboratory staff.
- Report
any significant problems, violations of the policies, practices, and
procedures set forth in the policies on the UCSD
Biosafety website
or
any significant research-related accidents and illnesses to the UCSD
Biosafety Officer within 24 hours.
- Notify
the UCSD Biosafety Officer immediately if a laboratory-acquired
infection is known or suspected.
- Be
adequately trained in good microbiological techniques.
- Ensure
that all research personnel are appropriately trained in biosafety and
receive appropriate medical surveillance.
- Develop
emergency plans for handling accidental spills and personnel
contamination.
- Create
and foster a
culture of safety
in the laboratory which encourages open discussion of biosafety issues,
problems, and violations of procedure. The PI will not discipline or
take any adverse action against any person for reporting problems or
violations to the Biosafety Officer or IBC.
- Comply
with all
applicable shipping
and
import/export requirements
for biohazardous materials.
- Submissions
of Proposed Work to the IBC
The PI shall:
a.
Understand
and recognize
the required levels of physical and biological containment in accordance with
the requirements set forth in the policies on the UCSD Biosafety website and the NIH r/sDNA guidelines.
b.
Select
appropriate microbiological practices and laboratory techniques to be used for
the research.
c.
Submit
an amendment to the BUA for all changes other than personnel to the IBC for
review and approval.
3.
Prior
to Initiating Research
The PI shall:
a. Submit
an amendment to the BUA for all changes other than personnel to the IBC for
review and approval.
b. Make
available to all laboratory staff the protocols that describe the potential
biohazards and the precautions to be taken.
c. Instruct
and train all research personnel in: (I) the practices and techniques required
to ensure safety, (ii) the procedures for dealing with accidents; and (iii)
biohazard risk assessment (iv) ensure lab personnel receive any
required EH&S training prior to commencing work.
d. Inform
the laboratory staff of the required
precautionary medical practices.
e. Ensure
that collaborators are made aware in advance of any biohazardous material sent
to them and the biosafety precautions to be followed.
4.
During
the Conduct of the Research
The PI shall:
a. Supervise the
safety performance of the laboratory staff to ensure that the required safety
practices and techniques are employed.
b. Investigate and
report any significant problems pertaining to the operation and implementation
of containment practices and procedures in writing to the UCSD Biosafety
Officer.
c. Immediately
notify the UCSD Biosafety Officer of any laboratory spills, accidents,
containment failure, or violations of biosafety practice which result in the
release of biohazardous material and/or the exposure of laboratory personnel
(or the public) to infectious agents and r/sDNA.
d. Correct work
errors and conditions that may result in the release of biohazardous materials.
e. Ensure the
integrity of all containment systems used in the project.
f. Restrict access
as required by the laboratory-specific biosafety practices procedures and by
the biosafety containment level approved by the IBC.
g. Conduct work in
compliance with all Federal, State, and University requirements.
h. Prepare, submit,
and obtain approval of a BUA and government agency permits as required (see II, above).
i.
Provides
initial and annual documented training of laboratory personnel and students for
existing projects and prior to initiation of new projects.
j.
Ensure
compliance with the Center for Occupational and Environmental Medicine
recommendations associated with projects.
k. Ensures
certification of all Class II and III biological safety cabinets at the time of
installation, annually, after the filter or motor is replaced or repaired, or
when a cabinet is moved.
l.
Ensures
certification of all in-place building HEPA filters serving BSL-3 laboratories at
the time of installation, annually, or when a filter is replaced or repaired.
- Individual
Employees
Whoever works in the laboratory in a technical
(rather than purely administrative) capacity is defined as a lab worker, even
if the person is a faculty member, a student, an intern, a visiting scholar, or
a volunteer.
The laboratory staff members are the most critical
element in maintaining a safe working environment. Each person must look out
for their own safety and that of their co-workers. If individuals do not follow
the University's and the laboratory-specific biosafety practices and procedures
in the conduct of their laboratory duties, we cannot have a safe working
environment.
The laboratory staff's responsibilities include:
- Conscientiously
follow lab-specific biosafety practices and procedures.
- Report to
the Principal Investigator (PI) or the
supervisor all problems, violations in procedure, or spills as soon as
they are identified. Report to the UCSD Biosafety
Officer any significant violations in biosafety policy, practices, or
procedures which are not resolved by the PI within a reasonable amount
of time.
- Refuse to
take any adverse action against any person for reporting problems or
violations of procedures to supervisors, the PI, the Biosafety Officer,
or the IBC.
- Become
familiar with the project and its associated potential hazards.
- Use
provided safety equipment.
- Participate
in mandated medical surveillance programs.
- Participate
in required safety training and ensure understanding of all elements of
the training and instruction.
- Follow
campus medical waste and hazardous waste disposal procedures
IV. PROCEDURES
A. UCSD Biosafety
Website:
http://blink.ucsd.edu/safety/research-lab/biosafety/index.html
V.
REFERENCES
- Federal Regulations
- U.S. Department of Agriculture
(USDA), Animal and Plant Inspection Service, National Center for Import
and Export
- Centers for Disease Control and
Prevention (CDC) - Additional Requirements for Transferring or Receiving
Select Agents
- Department of Transportation
(DOT) - Code of Federal Regulations Title 49 Parts 100-185 Shipping
Infectious Substances
- Code of Federal Regulations Title 42, Public Health, Sections
72 and 73.
- California Regulations
- California Code of Regulations,
Title 8, Chapter 4, Section 5193 "Bloodborne Pathogens"
- California Code of Regulations,
Title 8, Section 5199, “Aerosol Transmissible Diseases”
- California Health and Safety Code
(HSC) Section 117600-118360; "Medical Waste Management Act"
- San Diego County Code of
Regulatory Ordinances Title 6 Section 68.1201 "Medical Wastes"
(only as referenced by state regulations)
- Federal Guidelines
- National Institutes of Health
(NIH) "Guidelines for Research Involving Recombinant/Synthetic DNA
Molecules"
- CDC/NIH "Biosafety in
Microbiological and Biomedical Laboratories" (BMBL)
- National Research Council Guide
for the Care and Use of Laboratory Animals"
- USDA Biotechnology Guidelines.
- Professional Organization
Guidelines
- National Sanitation Foundation
International Standard 49, "Class II Biohazard Cabinetry"
- University of California Policies
and Procedures
- Contract and Grant Manual Section 3-400, University
Policy on Biohazards and Recombinant/Synthetic DNA.
- University Policy on Management of Health, Safety, and
the Environment.
- UC San Diego Policy Procedures
Manual 516-5.1
- UC San Diego Policy Procedures
Manual 516-5.2
- UC San Diego Policy Procedures
Manual 516-26