The Health, Safety and Security Department UNIVERSITY POLICY AND MANAGEMENT PROCEDURE Biological Agents Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 1 of 29 Statement This Management Procedure was approved and authorised by the Health, Safety and Welfare Committee on 11 November 2008 on behalf of the University of York Council and forms part of the Health and Safety Policy of the University of York. This document is a Management Procedure for good health and safety management practice. This Management Procedure provides Heads of Departments, College Provosts and all managers, staff and students with the necessary information to incorporate healthy and safe practices and relevant procedures into their activities. Divergence from this Management Procedure may result in Heads of Departments, College Provosts and the University being exposed to possible legal proceedings. The use of this Management Procedure and the incorporation of its requirements into working practices and activities will ensure that the University and its community achieves compliance with its legal duties with regard to health and safety. Date of Review Date of Last Review Date of Next Review May 2013 October 2010 June 2015 By By Director of Health, Safety and Security Director of Health, Safety and Security Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 2 of 29 Serial Content Page Statement 2 Content 3 Abbreviations 6 UNIVERSITY POLICY 7 1. OVERALL POLICY AND SCOPE 7 2. INTRODUCTION 7 3.1 3.2 EMERGENCY PROCEDURES AND NOTIFICATION OF ACCIDENTS Emergency Procedures Notification of Accidents 4. WHAT ARE BIOLOGICAL AGENTS? 5. 5.1 ROLES AND RESPONSIBILITIES Biological Agents Safety Committee (BASC) 5.1.1 Committee Membership 5.1.2 Terms of Reference University Roles 5.2.1 Biological Safety Advisor Departmental Roles 5.3.1 Project Supervisors Individual Workers (Includes all University Staff, Students and 5.3.2 Visitors) Equipment 5.4.1 Microbial Safety Cabinets 5.4.2 Autoclaves 5.4.3 Sealability Testing Estates Services 3. 5.2 5.3 5.4 5.5 7 7 8 8 9 9 9 9 10 10 10 10 11 11 11 12 12 12 ARRANGEMENTS 12 6. 6.1 6.2 6.3 12 12 13 13 13 13 14 6.4 RISK ASSESSMENT OF WORK ACITIVIES Activities Requiring Formal Assessment Risk Assessment Forms and Further Information Approval of Risk Assessments 6.3.1 GM Activities 6.3.2 Other Activities with Biological Agents Review of Risk Assessments Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 3 of 29 Serial Content Page 7. GENETIC MODIFICATION ACTIVITIES 16 8. REGISTER OF PATHOGENS 16 9. 9.1 9.2 LOCAL RULES What are ‘Local Rules’? Content of ‘Local Rules’ 16 16 17 10. 10.1 10.2 10.3 10.4 10.5 10.6 TRAINING AND SUPERVISION When is Training Required? Role of Supervisor/Group Leader Basic Local Training Requirements for all Workers Training Provided to non-Laboratory Staff Local Containment Level 3 Training Requirements Formal Training 10.6.1 Bio Safety (Including GM) Awareness of Workers 17 17 18 18 18 18 19 19 11. 11.1 OCCUPATIONAL HEALTH Immunisation 11.1..1 Tetanus 11.1.2 Hepatitis B Health Surveillance 11.2.1 What is it and when is it applied? 11.2.2 Animal Workers 19 19 19 19 20 20 20 12. 12.1 12.2 BIOLOGICAL SAFETY SIGNES Provision of Biohazard Warning Signs Where to use Biohazard Signs 20 20 21 13. 13.1 13.2 FACILITIES AND LABORATORY CONTAINMENT LEVELS Containment Levels Facilities 21 21 22 14. 14.1 14.2 14.3 14.4 14.5 FUMIGATION Introduction Risk Assessment and Procedure Monitoring Formaldehyde Levels Fumigating Microbial Safety Cabinets Fumigation of Laboratories 22 22 23 23 23 24 15. 15.1 15.2 DISINFECTION AND WASTE DISPOSAL Introduction Disinfection Autoclaving and Disposal of Waste from Containment Level 1 and 2 Facilities 25 25 25 11.2 15.3 Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED 25 Page 4 of 29 Serial Content Page 15.4 15.5 Autoclaving Waste from Containment Level 3 Facilities Autoclave Bag Holders 26 26 16. INSPECTION OF FACILITIES 26 17. 17.1 17.2 17.3 17.4 TRANSPORT OF BIOLOGICAL AGENTS General Transport in the United Kingdom Transport Abroad Importation of Biological Agents 17.4.1 Human Pathogens 17.4.2 Plant and Animal Pathogens or Materials that May Contain Them 27 27 28 28 28 28 29 18. 18.1 SECURITY Anti-terrorism Controls on Pathogens and Toxins 28 28 Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 5 of 29 Abbreviations ACDP Advisory Committee on Dangerous Pathogens ACGM Advisory Committee on Genetic Modification ACoP Approved Codes of Practice BASC Biological Agents Safety Committee BSA Biological Safety Advisor CoSHH Control of Substances Hazardous to Health DEFRA Department of Environment, Food and Rural Affairs DHSS Director of Health, Safety and Security EPA Environmental Protection Act GM Genetically Modified GMM Genetically Modified Microorganisms GMO’s Genetically Modified Organisms GMP Good Microbiological Practice HoD Head of Department HSE Health and Safety Executive HSSD Health, Safety and Security Department HMSWA Management of Health and Safety at Work Act PS Project Supervisors SACGMCoG The Scientific Advisory Committee on Genetic Modification Compendium of Guidance Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 6 of 29 UNIVERSITY POLICY 1. OVERALL POLICY AND SCOPE The University is committed to preventing or adequately controlling exposure to hazardous biological agents. This management procedure applies to all work activities involving the handling, use, transport and storage of biological agents, including genetically modified organisms (GMOs). 2. INTRODUCTION The purpose of managing activities involving biological agents (or materials that may contain them) is to prevent or minimise risks to human health and the environment and to set appropriate standards for control of those risks. The management procedure is based on the requirements of national legislation and extensive guidance produced by various expert technical advisory committees issued in support of the Regulations. 3. EMERGENCY PROCEDURES AND NOTIFICATION OF ACCIDENTS 3.1 Emergency Procedures The GMO Regulations only require emergency plans to be prepared if the risk assessment indicates that the health and safety of people outside premises, or the wider environment, may be affected. In practice, an emergency plan is unlikely to be necessary for most small scale activities or those involving low risk organisms. If an emergency plan is required, it should: Include measures to be taken in the event of an accident to which the plan relates Be reviewed and, where necessary, revised at suitably regular intervals. The person undertaking the activity should: Inform the emergency services and any body or authority liable to be affected by the accident Make the plan and any revisions of the plan publicly available. Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 7 of 29 3.2 Notification of Accidents The Contained Use Regulations refers to an accident as a significant and unintended release, either within the containment facility or to the environment, of GMOs which could cause harm to humans or the environment. Such accidents should be immediately reported to the BSA who will inform the DHSS, who will in turn inform the competent authority (HSE). This requirement is in addition to the requirement under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) to report accidents. Minor spillages within the containment facility of micro-organisms used in class 1 activities will not normally constitute significant releases of GMOs and will not routinely require notification. This is because they would be highly unlikely to affect people within the facility and will be easily dealt with so that they do not reach the environment. However, such spillages must be cleaned up with a validated disinfection procedure. 4. WHAT ARE BIOLOGICAL AGENTS? Biological agents include any microorganism, cell culture, or human endoparasite that may cause infection, allergy, toxicity or otherwise cause a hazard to human health or the environment. Biological agents (including GMOs) may be encountered in laboratories where: Microorganisms (bacteria, viruses, protozoa and some helminths) are intentionally cultured or used for teaching, research or for diagnostic purposes Cell cultures and samples of body tissues or fluids (human or animal origin) are handled Laboratory animals are kept Hazardous plants or plant materials are grown or used. Non-laboratory workers, such as Estates Services staff, may also be involved in activities that could lead to accidental exposure to biological agents. Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 8 of 29 5. ROLES AND RESPONSIBILITIES 5.1 Biological Agents Safety Committee (BASC) 5.1.1 Committee Membership The Biological Agents Safety Committee will consist of the following members: The Chair; appointed by Heads of Departments conducting GM/ pathogen work and ratified by the Health Safety and Welfare Committee Secretary Health and Safety Advisor (Biological Sciences) University Director of Health, Safety and Security Representatives of supervisors of work activities involving the use of GMOs and pathogens Representatives of all persons having access to facilities used for genetic modification and pathogen work, for example, technical staff, facility managers, Union representatives Co-opted members (internal or external to the University) to supplement existing expertise as and when necessary. The HSE will be notified of any significant changes to the membership. 5.1.2 Terms of Reference The Terms of Reference for the Biological Agents Safety Committee are to: Monitor the implementation of University policy and procedures relating to biological agents (including GMOs and other hazardous biological agents) to ensure compliance with legislative requirements Keep under review the health and safety measures in all departments relating to work involving biological agents and the contained use of GMOs Promote good practice by all those engaged in activities using biological agents Report to the Council through the Health, Safety and Welfare Committee Review, advise on, and approve all GMO risk assessments Review, advise on, and approve all risk assessments for biological agents requiring statutory notification to the competent authority (HSE) Keep under review any changes in relevant legislation and related approved codes of practice and guidance, and inform all departments concerned Receive and consider reports on facility inspections To meet at least once every term, and additionally as necessary To make all information relating to the committee’s activities freely available on request (subject to compliance with the Data Protection Act and any specific sensitivities relating to the work activities) Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 9 of 29 5.2 To advise Heads of Department on all matters relating to GMOs and dangerous pathogens The Biological Safety Advisor shall advise the Committee on all matters related to biological safety and, where necessary, report on the implementation of policy for the Committee’s consideration The committee will apply equality of opportunity for all individuals in its work. University Roles 5.2.1 The Biological Safety Advisor The Biological Safety Advisor shall be responsible for: Offer practical advice to individuals involved in activities using biological agents Advise the University, all departments and project supervisors of any changes to legislation and relevant codes of practice and guidance Ensure all statutory notifications are in place (includes premises and activity notifications) Check that facilities are appropriate Assist in the provision of suitable and sufficient training for those involved in activities using hazardous biological agents (see Section 10) Advise on the formulation of local rules (see Section 9) Ensure emergency plans are in place where required Assist in the auditing and inspection of GM facilities Authority to stop GM activities where the containment measures are considered insufficient to control the risks Maintain a record of risk assessments for all GM activities and other activities using hazardous biological agents Maintain a register of current GM activities and workers Maintain a register of all hazardous biological agents (typically Hazard Groups 2 and above) Liaise with external agencies on behalf of the University. 5.3 Departmental Roles 5.3.1 Project Supervisors Project Supervisors are defined as permanent members of staff who have been awarded a grant to conduct work with biological agents (including GMOs). They shall accept full responsibility for all aspects of safety for those working with them, including activities involving GMOs. Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 10 of 29 The Project Supervisor shall be responsible for: Ensuring that a suitable and sufficient assessment of risks is performed for all GM work activities and all other activities involving hazardous biological agents (typically those organisms in hazard group 2 and above) before the work starts Ensuring that risk assessments are reviewed whenever there are significant changes to the work and at least every 1 to 2 years to ensure that they remain relevant and up-to-date Ensuring that laboratory facilities meet the required standards and the BSA has inspected and approved the facilities before work starts Ensuring that all persons working under their supervision have received appropriate training (see Section 9) including awareness of risks and appropriate control measures to apply Ensuring that they provide or organise appropriate supervision to assess competence of persons under their control to work safely. 5.3.2 Individual Workers (Includes all University Staff/Students/Visitors) Ensuring that they comply with this Management Procedure Report any incidents, accidents or defects in equipment relating to the handling of biological materials to their Supervisor and the DSO/BSA Adopt safe practices in activities involving biological material, in particular to carry out the work only in designated areas, to wear appropriate protective equipment and clothing, and to dispose of waste in the specified manner Adopt good personal hygiene standards (including washing hands, no eating or drinking, no application of cosmetics or manipulation of contact lenses in designated areas) Co-operate with their supervisors and any other person appointed to advise or monitor health and safety in the local arrangements for biological safety. 5.4 Equipment Departments are responsible for the maintenance and testing of equipment used in biological containment facilities. This includes arranging the examination and testing of microbial safety cabinets and autoclaves used to inactivate biological waste material. 5.4.1 Microbial Safety Cabinets Microbial safety cabinets (a form of local exhaust ventilation) must be examined and tested at intervals not exceeding 14 months as required by the ‘Control of Substances Hazardous to Health’ (COSHH) Regulations. Cabinets should be tested more frequently (typically at six-monthly intervals) for Hazard Group 3 Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 11 of 29 organisms, especially for those organisms spread by airborne or droplet routes of infection. 5.4.2 Autoclaves Autoclaves must be serviced regularly as recommended by the manufacturers by a competent person according to a ‘written scheme of examination’. In addition, the pressure system must be inspected regularly (at least every 14 months) to establish it is fit for continued use. It is also essential that all autoclaves used to treat biological waste are calibrated annually. This will typically involve the use of calibrated thermocouples placed strategically within the chamber of each type of load normally treated. 5.4.3 Sealability Testing University Containment Level 3 facilities and some animal holding rooms are sealed to permit disinfection by fumigation, preventing escape of fumigant during the process. It is the responsibility of departments to arrange annual testing of these facilities to ensure their sealable status. 5.5 Estates Services Estates Services are responsible for the general maintenance of all laboratory and horticultural facilities. In addition, they are also responsible for the maintenance and periodic examination and testing of ventilation systems associated with laboratory rooms and connected to microbial safety cabinets. Records of maintenance/examination must be kept and made available for internal and external inspections. ARRANGEMENTS 6. RISK ASSESSMENT OF WORK ACTIVITIES 6.1 Activities Requiring Formal Assessment A suitable and sufficient risk assessment must be prepared in advance of the following work activities: All work involving the use of GMOs (includes work with GM microorganisms, plants and animals) All work involving human pathogens (Hazard Group 2 organisms and above) or materials that may contain them All work involving ACDP Hazard Group 1 organisms where a significant risk is identified Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 12 of 29 6.2 Work involving the use of Department for Environment Food and Rural Affairs (DEFRA) licensed plant and animal pathogens. Risk Assessment Forms and Further Information Copies of all risk assessment templates, along with further detailed information and guidance on their completion, are available on the web sites of the Department of Biology and the HSSD. 6.3 Approval of Risk Assessments All risk assessments for activities described above require approval before work commences. 6.3.1 GM Activities A summary of the risk assessment process for GM activities is outlined below in the Genetic Modification Risk Assessment Process Map. All Class 1 GM microbial activities or those involving transgenic plants and animals requiring standard containment measures must have provisional approval by the Biological Safety Advisor before work can start. The activity will also require review and final approval by the Biological Agents Safety Committee. All GM microbial activities assigned Class 2 or above, or transgenic plant and animal activities requiring a high level of containment (not provided by the standard measures), must have approval by the Biological Agents Safety Committee before work can commence. Some of these activities may also require notification to the Health and Safety Executive (HSE) and / or licence from DEFRA before work starts. 6.3.2 Other Activities with Biological Agents All activities involving the deliberate use of Hazard Group 2 organisms, or materials that may contain Hazard Group 2 organisms, or above must have the approval of the Biological Safety Advisor before the work commences. All activities involving Hazard Group 3 organisms or other biological agents requiring notification to the HSE must have the approval of the Biological Agents Safety Committee before work starts. All relevant licences from DEFRA must also be in place before work can start. Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 13 of 29 6.4 Review of Risk Assessments Risk assessments must be reviewed whenever there are significant changes to the work which alters the nature of the risks, and at least every 1-2 years to ensure that they remain relevant and reflect the risks of the current activity. A copy of the revised assessment, for an activity involving significant changes, must be sent to the Biological Safety Advisor for approval before work re-starts. Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 14 of 29 Genetic Modification Risk Assessment Process Map Health, Safety and Security Department Internal Process – Genetic Modification Risk Assessment Project Supervisor (PS) Prepares Risk Assessment for Genetic Modification (GM) activity Copy of GM Risk Assessment is sent to the Biological Safety Advisor (BSA) For approval All other GM Activities including: 1. GMM – Provisional Class 1 1. GMM Class 2 activities or above 2. Plants and Animals – Provisional low/ negligible risk requiring basis containment measures 2. High risk GM Plant and Animal work Work can ONLY commence after: Provisional approval given by the BSA (within 2 weeks) Make any necessary changes and wait for approval 1. Approval by full Biological Agents Safety Committee (BASC) 2. Any statutory notification period has lapsed 3. HSE Consent received (if required) YES NO GM Work Activity undertaken Management Procedure - Biological Agents (VS2.3 - May 13) Page 15 of 29 UNCONTROLLED DOCUMENT IF COPIED or PRINTED 7. GENETIC MODIFICATION ACTIVITIES Detailed information and guidance for work activities involving the use of GMOs is available on the Biology and HSSD web sites. 8. REGISTER OF PATHOGENS A register of all human (Hazard Group 2 or above), animal and plant pathogens is maintained by the BSA. Prior approval must be given by the BSA before new pathogenic organisms are brought to the University to ensure: Facilities are appropriate An approved risk assessment and ‘local rules’ are in place Any statutory notifications or licences (e.g. for plant and animal pathogens) are in place. 9. LOCAL RULES 9.1 What are ‘Local Rules’? Local rules or local codes of practice provide specific information on the arrangements or working practices for working safely day-to-day with biological agents (including GM Organisms) in the laboratory. They form part of the process of giving information on safe working, e.g. by serving as a checklist for identifying areas which staff should understand before being judged as competent. However, thorough training and instruction on their day-to-day application is needed for them to work effectively. Each laboratory must have clear documented local rules indicating the working practices that must be followed for activities in that laboratory. These should be freely accessible either by being put on display or through individual issues. The Research Group Leader/Principal Investigator of a given research group, or the supervisor/manager of a unit or work area, is responsible for ensuring local rules are in place and are complied with. A basic code of practice/local rules to cover work with hazard group 1 organisms requiring Containment Level 1 facilities can be based upon accepted good microbiological practice (GMP), as included in the description of CL1 requirements. Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 16 of 29 Model local rules should be tailored for local conditions and activities. The safe working practices adopted must reflect the assessment of risks involved, influenced by factors such as the biological agents involved and the type of work being carried out. Risk assessments should include cross-reference to the local rules. This pre-empts any need to write out or duplicate the information within the risk assessment and ensures consistency in standards. 9.2 Content of ‘Local Rules’ The Content and form of local rules/local code of practice should include: An introduction which explains the purpose of the local code of practice and the scope of activities covered, references other health and safety documents. Summarises the significant findings of relevant risk assessments Identification and description of the area to be covered and the containment level required to control the agents being used A description of the nature and range of agents which workers might be exposed to An outline of how workers are most likely to be exposed to infectious agents (i.e. the risks) and the safe working practices required to ensure work is done safely Local rules of conduct for workers and appropriate guidance for ancillary and maintenance staff, contractors and visitors Procedures for waste disposal and disinfection (routine and in the event of an emergency) Procedures for the maintenance, examination and testing of equipment such as microbial safety cabinets Emergency procedures, including the procedures for dealing with accidents and incidents involving biological agents, and who should be contacted in the event of an accident involving an injury or infection Health Surveillance arrangements and immunisation policy if required, A list of general procedures specifying which workers are authorised to carry out particular procedures Key training requirements for workers and training records demonstrating that training has been provided. 10. TRAINING AND SUPERVISION 10.1 When is Training Required? Training will be required for all persons: On recruitment Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 17 of 29 10.2 When a significant change to work, equipment, work activity or responsibilities takes place, especially where increased risks may be involved For refresher training (where appropriate) to maintain standards. Role of Supervisor/Group Leader The project supervisor is responsible for ensuring that all their workers receive adequate training. In addition, the supervisor must monitor the work to ensure that working practices are being adhered to. The level of training provided should be appropriate to the level of risk and complexity of the work being undertaken to ensure competence of workers. 10.3 Basic Local Training Requirements for all Workers Basic local training requirements for workers must include information on: The nature of the hazards being used The risks (to human health and the environment) likely to be encountered in their work Preventive and protective measures used to control risks The requirements of the local rules/local code of practice, including the safe working practices and procedures to be followed e.g. disinfection, waste disposal, transport, storage and emergency spillage Safe use of equipment such as the microbial safety cabinet Procedure for reporting accidents. All persons should also receive appropriate supervision as provided by, or organised by, the project supervisor. This should be related to the level of work to ensure that standards are maintained. Once satisfied with the competence of the worker, the supervisor can allow them to continue without constant supervision. 10.4 Training Provided to Non-Laboratory Staff Training should not be limited to those working at the bench. Other staff such as cleaners, porters, maintenance staff, external contractors must also receive appropriate information, instruction and training about the hazards that they may encounter when working in the laboratory. 10.5 Local Containment Level 3 Training Requirements Training requirements at containment level 3 are more detailed and formal. In addition to those requirements outlined above for all workers, key competencies for those working at CL3 include: Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 18 of 29 Full understanding of emergency procedures e.g. emergency room or cabinet fumigation Full training where applicable on fumigation procedures. Written records of training are an essential requirement for all individuals working at Containment Level 3. These should include details of what training has been provided and signed off by both the trainer and trainee. 10.6 Formal Training 10.6.1 Biological (Including GM) Safety Awareness Training for Workers All individuals working with GMOs or pathogens are expected to attend the formal ‘Biological (Including GM) Safety Awareness Training for Workers’ training session organised once a term (further information and details). The main aims of this course are to explain the purpose of the regulations and typical containment measures used to protect human health and the environment. 11. OCCUPATIONAL HEALTH 11.1 Immunisation Immunisation and regular booster injections should be given, if appropriate, as a supplementary safety precaution for those who may be exposed to pathogenic microorganisms. Immunity levels should be checked before or after immunisation where this is provided as a control measure against infection. The University’s Occupational Health Advisor is available to give confidential advice to individuals that may require immunisation. 11.1.1 Tetanus All staff and students are strongly advised to check with their General Practitioner (GP) that they have had a full course of Tetanus. This is particularly important for those whose work may bring them into contact with soil and animals. 11.1.2 Hepatitis B Laboratory workers processing samples containing human blood and body fluids are recommended to get immunised against Hepatitis B (if not already), by contacting the University’s Occupational Health Advisor (OHA). Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 19 of 29 11.2 Health Surveillance 11.2.1 What is it and when is it applied? Health Surveillance is typically applied if working with a hazardous substance (including biological agents): That produces an identifiable disease or adverse health effect that can be related to exposure. Where there is reasonable likelihood that the disease or effect may occur under the conditions of work. For which there are valid techniques for detecting the disease or effect. The GMO Regulations do not include a specific requirement for health surveillance for GM work. The University’s OHA should be contacted for further information or advice on health surveillance requirements. 11.2.2 Animal Workers All staff, postgraduate and undergraduate research workers must register for health surveillance before working with animals. This involves: Pre-employment screening/pre-access to animal facility screening Health monitoring (after 6 weeks, 6 months followed by yearly) involving health questionnaire and lung function test. 12. BIOLOGICAL SAFETY SIGNS Signs should be provided where there is a residual risk to persons, even after applying all the appropriate control measures to reduce risk. This relates to provision of biohazard warning signs and signs indicating that access is restricted and, where appropriate, who is authorised to enter. 12.1 Provision of Biohazard Warning Signs It should be emphasised that biohazard warning signs should be used sparingly. They must only be used to warn of a biological hazard. They should be placed at the entrance to containment facilities, on safety cabinets and on incubators and storage equipment outside the facilities. They may also be placed on large items of equipment inside the facility and biohazard tape may be used to mark areas of bench where microbiological hazards are handled. Biohazard signs are primarily intended for areas where there is a risk of infection and not for other biological risks (e.g. biting or scratches, toxins or Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 20 of 29 dangerous animals). Biohazard signs should be maintained in good order and must be removed when they are no longer relevant. 12.2 Where to use Biohazard Signs Biohazard signs must be used: Where ACDP or ACGM Group 3 hazards are handled in laboratories or other facilities Where ACDP or ACGM Group 2 hazards are handled in the laboratory provided there is a significant risk that accidental exposure would lead to infection Where animals are infected (deliberately or otherwise) with organisms pathogenic to humans and where there is a significant risk that accidental exposure would lead to infection. Biohazard signs may be used: Where ACDP or ACGM Group 2 hazards are handled but the risk is minimal Where human tissue is stored or used. Other signs, e.g. where access is restricted or by authorised persons only, should be provided to indicate the restrictions and, where appropriate, the persons authorised to enter or use equipment. The containment level of the facility should also be indicated on the biohazard warning sign to indicate whether the facility is level 2 or 3. 13. FACILITIES AND LABORATORY CONTAINMENT LEVELS 13.1 Containment Levels Deliberate work with biological materials, including wild-type microorganisms and GMOs, is normally undertaken in containment laboratories. There are four different levels of containment (levels 1 – 4) for laboratory work, each containment level being directly related to each equivalent Hazard Group. Thus organisms categorised as Hazard Group 1 (lowest hazard rating) should normally be handled in Laboratory Containment Level 1 facilities, and likewise up to Hazard Group 4 (highest hazard rating) in Containment Level Four facilities (none located within the University). The requirements of each laboratory containment level are made up of a combination of physical parameters and work practices. Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Details of the Page 21 of 29 containment measures are defined by three similar, but separate systems of containment from: Advisory Committee on Dangerous Pathogens (ACDP) Advisory Committee on Genetic Modification (ACGM) Department of Food and Rural Affairs (DEFRA). The level of containment under which particular work should be undertaken is determined as part of the risk assessment. The standards required are described in legislation and supporting guidance. Where the work involves the use of, for example, a human and animal pathogen, a combination of the standards for all relevant containment levels will be required. 13.2 Facilities Work with biological materials must only be undertaken in facilities that are suitable for the purpose and approved by the Biological Safety Advisor. The standards required are described in the legislation and supporting guidance. Such facilities are described as containment laboratories or rooms. There are different levels of containment and the one required for a particular work activity is determined as part of the risk assessment process. The Group Leader has a responsibility to ensure that the level of containment required for a particular facility is correctly identified to those involved in the design and/or refurbishment of containment facilities, including the relevant Estates Services and Buildings Project Manager and the BSA. The Group Leader should also ensure the requirements of the department and workers who will use the facility are made clear and taken into account in the design process. The Head of Estates Operations is responsible for ensuring that all new building and refurbishment work in containment laboratories meets the required/agreed specification. 14. FUMIGATION 14.1 Introduction Microbiological safety cabinets and some facilities, including Containment Level 3 laboratories and some animal rooms, are periodically fumigated to inactivate any hazardous biological agents that may be present. Fumigation with formaldehyde vapour is a recognised and commonly used method for this type of equipment and facility. Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED However, formaldehyde Page 22 of 29 vapour has irritant and toxic properties and carries a risk of respiratory and / or skin sensitisation reactions. At the higher concentrations used for room fumigations it is extremely hazardous and exposure to such levels, even for a short time, could result in very serious harm. Fumigation systems using hydrogen peroxide are available and increasingly being used as an alternative to formaldehyde vapour. Although such chemicals are less hazardous than formaldehyde, there are still risks associated with the procedures and appropriate control measures are required in order to carry out the work safely. 14.2 Risk Assessment and Procedure A detailed risk assessment and procedure must be documented and approved by the Biological Safety Advisor in advance of all fumigation activities. All laboratory groups are responsible for ensuring appropriate systems are in place to provide safe and suitable procedures for fumigation in biological laboratories and associated facilities. In conjunction they must ensure adequate and appropriate instruction, training and supervision is provided for workers undertaking fumigation procedures. They should also ensure that suitable arrangements are in place to monitor and review working practices. 14.3 Monitoring Formaldehyde Levels If formaldehyde vapour is used as a fumigant, it is important that the long term (8 hour time weighted average reference period) and short term (15 minute reference period) ‘workplace exposure limit’ of 2 ppm is not exceeded at any stage of the process. A formaldehyde meter is available from the Biological Safety Advisor to monitor levels during the fumigation procedure. 14.4 Fumigating Microbial Safety Cabinets Microbiological safety cabinets used to handle hazardous microorganisms (i.e. Hazard Group 2 organisms or above), must be fumigated in the following circumstances: After a major spillage or a spillage where inaccessible surfaces have been contaminated Before any maintenance work on the cabinet where access to potentially contaminated parts is necessary (including filter and pre-filter changes) Before carrying out filter penetration tests When there are any changes in the nature of the work that result in significantly different risks. Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 23 of 29 Fumigation must be carried out only by a trained responsible person with adequate knowledge of the procedure and the precautions to be followed. Where the cabinet has been used for hazardous microorganisms, HEPA filters should be handled only with appropriate protective clothing (laboratory coat and heavy duty gloves) even after fumigation. Such filters must either be autoclaved prior to disposal in the ‘offensive waste’ stream or be securely wrapped in yellow bags for disposal as clinical waste. The cabinet must be sealed before fumigation to prevent leakage of formaldehyde into the laboratory. It should be checked to ensure that the closure panel/‘night door’ has been properly and securely located and a good seal has been achieved. Where necessary sealing tape should be used to ensure there is no leakage. With Class III or hybrid (Class I/Class III) cabinets a blanking plate should be fitted over the inlet filter. If the cabinet is a recirculation type, there must be a safe means of venting the formaldehyde vapour to atmosphere (the outside) such as by the use of a fumigation adaptor kit (see below). This must be fitted to the cabinet prior to commencing fumigation. 14.5 Fumigation of Laboratories Formaldehyde fumigation of laboratories or other rooms must be carried out only by named trained personnel. Fumigation procedures for Containment Level 3 facilities must be validated to demonstrate decontamination efficacy. This involves undertaking test fumigation with spore strips being placed at strategic locations around the laboratory. Prior to undertaking fumigation with formaldehyde vapour, it must be thoroughly checked and confirmed that the room is properly sealed and there will be no release of gas to other areas. Any significant escape of formaldehyde would constitute an uncontrolled release of a hazardous chemical and would be a reportable incident to the Health and Safety Executive. There must be a means of exhausting the formaldehyde vapour from the laboratory/room that avoids the need for any person to enter the area where the formaldehyde has been released. The extract must be a total loss system with no possibility of formaldehyde being ducted to other areas. This could be by the Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 24 of 29 use of a ducted microbiological safety cabinet to exhaust the fumigant to atmosphere and via room extract ductwork. The recognised method is to have a switch external to the room to allow extraction of the formaldehyde without entering the room. The Biological Safety Advisor must be consulted before any other method is adopted. It should also be possible to operate, without entering the room, any dampers that may be installed if their opening is necessary to ventilate the room. A record must be kept, for at least 5 years, of all fumigations of rooms/laboratories including date, personnel involved and the results of air monitoring on completion of the procedure. 15. DISINFECTION AND WASTE DISPOSAL 15.1 Introduction All biological material (liquids and contaminated solids) must be inactivated before release from departmental facilities. Typical methods used include disinfection and sterilisation by autoclave treatment. 15.2 Disinfection The use of chemical disinfectants, normally in the form of proprietary products specifically for use in laboratories, is a widespread and important control technique in biological laboratories. Laboratories handling microorganisms and other hazardous biological materials should routinely use appropriate disinfectants, effective against target organisms, to decontaminate surfaces and equipment, and prevent microbial growth in spent culture fluids etc. Each laboratory group must ensure there is a clear documented disinfection policy indicating suitable concentrations, contact times and applications for all disinfection requirements within the group. 15.3 Autoclaving and Disposal of Waste from Containment Level 1 and 2 Facilities Containment level 1 and 2 facilities should have access to an autoclave either within the laboratory suite or elsewhere within the building. If the waste is transported to autoclave facilities outside a laboratory suite, a robust, leak proof container should be used. Autoclaved waste from CL1 and CL2 facilities is routinely placed in ‘offensive Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 25 of 29 waste bags’ by the autoclave technicians and disposed of via the ‘offensive waste’ route via a contractor. 15.4 Autoclaving Waste from Containment Level 3 Facilities Containment Level 3 (CL3) facilities must have an autoclave either within the laboratory or within the laboratory suite itself. Only authorised staff should undertake the decontamination of waste. If the waste has to be removed from the CL 3 facility for autoclaving in an adjacent laboratory, it must be transported in a robust, leak proof container fitted with a lid. The lid of the container should only be removed when the container has been placed in the autoclave to allow steam penetration. The autoclave must be available for immediate use once the waste arrives. This requires close co-ordination between the staff of the CL3 laboratory, and those in charge of the autoclaving facilities. The container must be surface decontaminated with a suitable disinfectant before removal from the containment laboratory. Autoclaved waste from CL3 laboratories must be disposed of in the Clinical Waste Bins, for collection by an authorised disposal company, before final incineration. 15.5 Autoclave Bag Holders Autoclave bag holders must be appropriate for the laboratory facility and type of material to be autoclaved. Laboratories handling pathogens must use either an autoclaveable bin or traditional autoclave bag stand (with or without foot operated lid). Standard plastic bins are only acceptable for work activities involving non-pathogenic organisms operating at Containment Level 1, and these should be periodically disinfected. To avoid unnecessary problems with contamination, plastic bins should be used without manually operated lids, unless required for containment of materials such as GM seed. 16. INSPECTION OF FACILITIES Facilities handling hazardous biological agents will be subject to scheduled inspections as organised by the Genetic Modification & Dangerous Pathogens Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 26 of 29 Safety Committee. The inspection process aims to assess the: Suitability of the general facilities (laboratory or greenhouse) Suitability of working practices and whether they are being followed Awareness of the hazardous nature of organisms used by workers and how harm could arise (i.e. the risks) Understanding of the relevance and need for specific containment measures. Inspections will be prioritised, with particular attention given to facilities handling the most hazardous organisms and those facilities that give most concern. 17. TRANSPORT OF BIOLOGICAL AGENTS 17.1 General Certain biological samples, cultures and other materials fall within the description of dangerous goods for carriage and both national and international legislation demand stringent requirements must be met if the goods are transported by any means. All workers in the University must ensure Regulations applicable to the transport of biological materials are complied with for each particular consignment and not carry, consign, package or play any other role in the transport chain if they are not competent to do so. The Department of Biology Supplies & Goods Services staff or the Biological Safety Advisor should be contacted for advice on the requirements for transportation of biological agents in the UK or abroad. All persons undertaking any role in the transport chain must be properly trained and have an understanding of the relevant Regulations to ensure they are able to undertake their responsibilities to the required standards. Even if the particular biological material to be transported is not hazardous and does not fall under the description of dangerous goods, the item still must be packed safely for carriage. Any problems occurring during transport, such as leakage or breakage, should be reviewed in order that corrective measures can be taken to prevent any recurrence. If workers in the University receive packages that are not properly packaged or labelled they should contact the originator to advise of the problem and ask that any future packages meet the legislative standards. Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 27 of 29 17.2 Transport in the United Kingdom Department of Biology Supplies and Goods Services should be contacted for guidance on transport of biological materials in the UK. 17.3 Transport Abroad For transport of samples abroad, anyone sending biological materials by air must ensure they comply with the IATA Dangerous Goods Regulations. Department of Biology Supplies and Goods Services should be contacted for guidance on transport of biological materials abroad. 17.4 Importation of Biological Agents 17.4.1 Human Pathogens There is no requirement under health and safety law to obtain a licence to import human pathogens into the UK, other than the requirement under COSHH to notify the movement of HG4 agents. There is a requirement to notify first use of HG2-HG4 agents at particular premises, but this relates to use of agents in the laboratory, not the consignment of those agents. This only applies to human pathogens; licences are required for the importation of animal and plant pathogens (see below). Contact Biological Safety Advisor for further information if required. 17.4.2 Plant and Animal Pathogens or Materials that May Contain Them Importation of certain plant and animal pathogens, or pests, or any material (e.g. soil) that may be carrying such pathogens or pests, is strictly controlled by legislation enforced by Department of the Environment, Food and Rural Affairs (DEFRA). Rigorous licensing requirements are in place for both import and possession of many types of materials. Contact the BSA for further information if required. It is the responsibility of the individual importing the material to obtain any licences required. 18. SECURITY 18.1 Anti-terrorism Controls on Pathogens and Toxins Certain pathogens and toxins are controlled under the Anti-terrorism, Crime and Security Act 2001. The controlled agents are listed in Schedule 5 of this Act. Particular reference should be made to the notes accompanying Schedule 5 detailing that the legislation extends: Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 28 of 29 In the case of pathogens - not only to include the pathogen itself but also any genetic material containing any nucleic acid sequence associated with the pathogenicity of the micro-organism and any genetically modified organism containing any such sequence In the case of toxins (reference to which includes subunits of the toxin) not only to include the toxin itself but also any genetic material containing any nucleic acid sequence for the coding of the toxin and any genetically modified organism containing any such sequence. Under this legislation, the holding, be it in storage or in use, of any microorganism or toxin or relevant genetic material on Schedule 5, is subject to notification to the Home Office. There are some exceptions to this requirement (for example for some toxins if the quantity held is less than 5mg) as detailed in The Security of Pathogens and Toxins (Exceptions to Dangerous Substances) Regulations 2002. Any notifications that need to be made to the Home Office for holdings within the University will be made by the HSSD. Individuals who have any materials controlled under this legislation should inform the University BSA of any holdings on University premises, or in advance of any intentions to acquire such material, in order that the relevant notification can be made to the Home Office. The HSSD will co-ordinate notifications and is the primary point of contact for the Home Office, and for the Police Counter-Terrorism Officer, in this regard. All enquiries individuals receive from any sources about such materials must be referred to the HSSD before any information is provided. Management Procedure - Biological Agents (VS2.3 - May 13) UNCONTROLLED DOCUMENT IF COPIED or PRINTED Page 29 of 29
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