Level 3 –
H&S Policy
Structure
Working with Genetically Modified
Organisms
BACKGROUND
 This policy deals with the health and safety, and legal compliance, aspects
of work with genetically modified organisms (GMOs).
 “Genetically modified organism” means any living organism derived from,
or containing, a genetically modified cell. It can be a plant, animal or
microorganism.
 Genetic modification (GM), also referred to as genetic manipulation and
genetic engineering, has been developing since 1973. GMOs can be
used in contained facilities (as at the University) or deliberately released
or grown in the environment as GM crops and animals.
LEGISLATION
The Genetically Modified Organisms (Contained Use) Regulations 2014

These cover the use of all genetically modified organisms (GMOs) used in
contained facilities, not released into the environment. “Use” includes the
construction, culturing, storage, transportation, work area
decontamination, inactivation and disposal of GMOs.

In Regulation 4, The Health and Safety at Work etc Act 1974 is modified
to ensure students undertaking contained use GM work in an educational
establishment, such as a university, are treated as employees for the
purposes of the 1974 Act.

The University is required to constitute a Genetic Modification Safety
Committee (GMSC), to oversee GM work and comment on GM project
proposals. All work with GMOs at the University must be authorised by
the University GMSC.

All people working with GMOs must be registered with, and approved by,
the GMSC.

The HSE must be notified before the start of any work involving GM
projects at Class 2 or above.

Control measures must include the general principles of good
microbiological practice (GMP) and good occupational safety and health
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(GOSH) detailed in Schedule 7 of the GMO (Contained Use) Regulations
2014.
UNIVERSITY POLICY

The University of Bath aims to achieve the highest working standards that
are reasonably practicable for all work with genetically modified organisms
in order to safeguard the health and safety of its staff and all persons that
might be affected by those activities.

It is the commitment of the University to reduce the risk of unintentional
release of, or exposure to, genetically modified organisms and toxins, and
to protect the environment.
RESPONSIBILITIES
Employees
Will read relevant risk assessments and comply with the required control
measures, such as wearing suitable lab coats, conducting work in a safety
cabinet, transporting GMOs in secure containers and observing waste
disposal protocols.
Will report any incident, accident or defect in equipment relating to the
handling of GMOs to the specialist adviser via the University Health,
Safety and Environment Service.
Will seek advice and register with the Genetic Modification Safety
Committee to work with genetically modified organisms.
Will cooperate with their supervisors, Health & Safety Advisor, Specialist
Health & Safety Officers/Advisors or any other person appointed by the
University to monitor biological safety.
Line Managers
Will inform the GMSC via [email protected] prior to working or
supervising work with GMOs at the University of Bath.
Will ensure that University policy, procedures and safe systems of work
are strictly adhered to in order to ensure compliance with all relevant
legislation relating to the use of GMOs (including ordering and acquisition,
constructing, growth, transport, storage and disposal).
Will ensure that microbiological agents are classified into 1 of 4 hazard
groups (defined in ACDP’s Approved List of biological agents), according
to their hazard, and are securely stored.
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Will assess the risks of GMOs before work starts, considering in particular;
(a) The hazard groups of any biological agents that may be present and
what form they may be in, e.g. infectious stages or hardy spores;
(b) How and where they are present, how they are transmitted and the
diseases they cause; and
(c) The likelihood of exposure and consequent disease (including the
identification of people who may be particularly susceptible, for
example because they are immunocompromised), drawing on
evidence of the prevalence of infection or other ill effect as
experienced within a particular industry sector or workplace.
The risks associated with GMOs and contaminated waste material should
be assessed at each stage of handling, for example during construction,
growth, expression, harvesting and waste disposal.
Will ensure that all GMO risk assessments are notified to the GMSC, and
that all people planning to work on authorised projects are registered with
the GMSC. The GMSC can be contacted at [email protected]
Will ensure that any relevant licence (e.g. from DEFRA) is obtained for
work with animal or plant GM pathogens.
Will ensure that any fees payable to HSE for notification of projects
assigned as Class 2 (or above) are paid when the project assessment is
sent to the HSE.
Will ensure that all workers are competent to work with GMOs, by ensuring
they are adequately informed, instructed, trained and supervised. An
assessment of competence should be carried out on all persons new to
the project and new to a type of work or risk category.
Heads of Department
Will ensure that their members of staff are aware of, and adhere to,
University policy, procedures and safe systems of work in order to ensure
compliance with all relevant legislation relating to the use of GMOs.
Will ensure sufficient resources are provided to adequately maintain and
test controls such as autoclaves and microbiological safety cabinets.
Will ensure that biohazard signs (image on right) are
displayed and maintained on the doors of facilities housing
Class 2 GM projects, and security arrangements are
implemented to prevent unauthorised access in areas
identified by biohazard signs.
Head of University Health, Safety & Environment Service
Will ensure a University Genetic Modification Safety Committee is
constituted, and relevant employee safety representatives are invited to sit
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on it.
Will ensure that, under the Management of Health and Safety Regulations
1999, appointments will be made, in writing, of any specialist Health &
Safety Officers/Advisers to support the GMSC.
Will produce and review this policy biennially or after any significant
change whichever is the soonest.
Chair of the University Genetic Modification Safety Committee
Will ensure that the Committee be comprised of sufficient members to
provide expertise on any project coming before the GMSC.
Will comment on proposals for work involving GMOs, and authorise such
proposals as well as the personnel planning to do GM work.
Will identify additional training needs for personnel who cannot
demonstrate competence to work with GMOs.
Will ensure that Local Rules and protocols for the safe and contained use
of GMOs are published.
Specialist Health & Safety Advisors/Officers
Will advise on the occupational aspects of work with any biological
material, as well as liaising with the enforcing authorities for work with
Hazard Groups 3 and 4 microorganisms and relevant toxins.
Will coordinate the training of personnel needing competence in
performing work with biological agents, particularly genetically modified
microorganisms.
Will check that controls such as autoclaves and microbiological safety
cabinets are adequately maintained and tested by departments.
Will advise Heads of Departments on matters relating to the containment
of biological hazards and the safety of staff, with particular reference to
the Genetically Modified Organisms (Contained Use) Regulations 2014
and other relevant legislation and codes issued by the Scientific Advisory
Committee on Genetic Modification.
Will act as the contact point for GM work with the enforcing authority.
Will implement an audit programme to ensure that risk control systems
are maintained and remain effective.
Will maintain a register of those working in the genetic modification field
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and ensure that staff registered to work in this field have suitable
training, instruction and supervision.
Will monitor the following safety aspects of genetic modification work
within the University;
o that local rules are followed
o that appropriate training in good microbiological practice is given
o that accidents are investigated, remedial actions are taken where
necessary and appropriate records are kept
o that recombinant organisms and pathogenic or potentially
pathogenic material are stored in a safe way and that appropriate
records are kept
o that recombinant organisms are transported in a safe way
FURTHER INFORMATION
There are guidance notes and further information available on the Staying
Safe and Well website with a link to the GM wiki
Legislation and official guidance;
The Genetically Modified Organisms (Contained Use) Regulations 2014
 A Guide to the Genetically Modified Organisms (Contained Use)
Regulations 2014
 Scientific Advisory Committee on Genetic Modification, Compendium of
Guidance
The Anti-terrorism, Crime and Security Act 2001
 Schedule 5 list of toxins and pathogens
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