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Biosafety/Biosecurity: An Update

Biosafety/Biosecurity: An Update. February 27, 2004. Where is the emphasis?. Biosafety   Biosecurity. Biosafety. Policy Handbook 1200.8 “Safety of Personnel Engaged in Research” VA Directive 7701 & Handbook 7701.1 “Occupational Safety & Health” OSHA’s regulations Plans

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Biosafety/Biosecurity: An Update

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  1. Biosafety/Biosecurity: An Update February 27, 2004

  2. Where is the emphasis? Biosafety   Biosecurity

  3. Biosafety • Policy • Handbook 1200.8 “Safety of Personnel Engaged in Research” • VA Directive 7701 & Handbook 7701.1 “Occupational Safety & Health” • OSHA’s regulations • Plans • Minor updates to 1200.8 • Revise biosafety form (10-0398) • Define training needs

  4. Role for Research Biosafety • Ensure safety of personnel • Identify hazards: chemical, physical, and biological • Incorporate into VAMC wide occupational safety program, fire safety, PPE and precautions • Safety & health inspections: local, VA CO, or others • Policies, plans and procedures

  5. Hazard Categories • Chemical: corrosive, toxins, carcinogens, mutagens, flammables, explosive • Physical: ionizing and non-ionizing radiation, noise, temperature extremes, electrical mechanical • Biological: pathogens, organism, recombinant DNA, toxins produced by organisms and human or animal tissue, body secretions, & blood

  6. Biosecurity • An increasing concern • Effects all research laboratories • Special emphasis on BSL-3s & labs with select agents or toxins • Required revising Directive 2002.075 (Control of Hazardous Agents) • Draft is unofficial & in concurrence

  7. The Concurrence Process Draft Concurring Offices  Final Document

  8. Control of Hazardous Agents(Why The Re-draft) • Approach: • Facility’s comprehensive program • Address concerns of IG • Meet new standards • HHS (CDC) • USDA (APHIS) • Clarify current requirements

  9. Control of Hazardous Agents Program • A unified approach • Integrates: • VAMC safety & security program and • Research safety & security program • Medical Center Director (MCD) is responsible institutional official • Requires coordination and cooperation of many offices

  10. Definition:Select Agents (SA) & Toxins • SA: Group of agents designated by HHS/CDC as requiring registration with CDC lab registration program • Viruses, bacteria, rickettsiae, fungal, toxins, recombinant DNA • Biological agents and toxins (USD/APHIS): agents with potential to be severe threat to animal & plant health -- Labs must also register • Overlap agents: found in CDC & APHIS lists • Directive refers to CDC & APHIS agents collectively as SA & toxins

  11. Definition: Hazardous Agents • Hazardous agents include: • Select agents & toxins • Exempt quantities of toxins • Other hazardous chemicals • Radioactive material • Sensitive material • List in Directive 2002-075 and draft directive

  12. Control of Hazardous Agents Program (cont) • Based on regulatory, scientific & ethical principals • Relevant policies and regulations • VHA Research & non-research • HHS/CDC • USDA/APHIS • Dept. of Commerce • Dept. of Transportation • EPA • OSHA

  13. Roles and Responsibilities • MCD is the Responsible Official • ACOS/AO • Research point of contact • Liaison with VAMC committees, personnel, police etc • Personnel, lab access, resources • Annual assessments and drills • Role with R&D committee/SRS • Ensure compliance

  14. Roles and Responsibilities: R&D/SRS committee • Advises the MCD on the R&D program • R&D responsibilities: • M-3, Part 1, Chapter 2 & 3 • Safety of Personnel in Research (1200.8) • Hazardous Agents directive • R&D committee may form a Subcommittee on Research Safety (SRS) • SRS = Institutional Biosafety Committee (IBC)

  15. SRS/IBC: A Special Issue • Research on recombinant DNA & gene transfer • Regulated under NIH Guidelines • Incorporated into VHA policy • IBC • Specific membership • Specific responsibilities • Specific requirements • www4.od.nih.gov/oba

  16. Roles and Responsibilities: R&D/SRS committee • In addition to other responsibilities • Ensure biosafety review completed & determines need for changes to protocol • Oversee requests for lab registration • Reviews requests for: • Lab access & access to BSL-3/SA labs • Purchase transfer or destruction of SA & toxins • Policies & procedures • Results of vulnerability assessments, drills, incidents • Document all reviews and findings

  17. Roles and Responsibilities: Biosafety Officer Varies from institution to institution • Expertise: science, safety, security, & applicable policies • Responsible for or delegates: • Training (delivery & record keeping) • Inventory control • Vulnerability assessments/drills • Ensure compliance • POC and resident expert

  18. Roles and Responsibilities: Lab Directors & Investigators • Ethical conduct of research • Compliance with regulations • Handook1200.8, Directive 2002-075 • Select agents (SA) & toxins • BSL-3 • Safety & security within the lab • All lab staff • Trained • Work within their scope of work • Inventory control

  19. Responsible Official & Alternate Responsible Official • Term specific to select agents & toxins regulations (CDC: 42 CFR 73; APHIS: 7 CFR 331, 9 CFR 121) • RO = MCD • Alternate RO can be the Biosafety Officer, ACOS, AO, other qualified person

  20. Responsible Official (RO)Alternate Responsible Official • Approved security risk assessment • Ensure facility compliance • Alternate RO • Delegated authority from RO • Day to day operations • Knowledgeable (regulations, policy, science) • Coordinate with non-research offices: Human Resources, Police, Safety, etc.

  21. Control of Hazardous Agents:Specific Requirements 1. Controlling lab access 2. Physical security 3. Registering labs for select agent or toxin use 4. Inventory control 5. Emergency preparedness 6. Training 7. Policies and procedures/plans

  22. Controlling Laboratory Access • Approve/authorize all staff (paid & WOC) • Approve for all labs • HRM “credentialing” • OPM background check (SF 85) • Authorize for SA & toxin labs • HRM procedures plus • Security Risk Assessment (FBI Form FD 961, approval by CDC or USDA) • Visitors/visiting scientists, students, etc. escorted at all times unless approved or authorized

  23. Physical Security: A Two Tiered System • Laboratories in general • Security is for research area • Individual labs: ordinary locks • BSL-3s and labs with SA or toxins • More sophisticated security • Ensures 2 security perimeters • 3rd perimeter: locked refrigerators/cabinets

  24. Physical Security All Laboratories • Control access 24/7 • Keycard or more sophisticated system that records access • Doors self-closing • Intrusion alarm integrated into VAMC • Video surveillance at entrances suggested • Unobstructed view of exterior entrances

  25. Physical SecurityBSL-3s & Labs with SA or Toxins • Security requirements apply to: • BSL-3 without Select Agents or Toxins • BSL-3 with SA or Toxins • Laboratories using SA or T • Storage areas for SA or T

  26. BSL-3s and SA or Toxins Security Requirements • Security as required by Select Agents regulations (CDC or APHIS) • Cardkey or more sophisticated system • Code/keys specific to the laboratory • Must record entrance & egress • Access only to those who work in lab • For SA & toxin labs: Authorized (approved Security Risk Assessment & MCD concurrence) • Special approval: BSL-3 without SA or toxins

  27. BSL-3s and SA or Toxins Security Requirements (cont.) • Audible alarms monitored by police • Telephone in lab • Video surveillance • Lock all containers when out of site, not in use • Meet requirements in Handbook 0730 “Security and Law Enforcement for: • Windows • Doors • Overhead spaces

  28. Registering Labs for SA or Toxin Use • Can NOT begin using SA or toxins unless: • Lab registered • All staff are authorized & have approved SRA • Registration by HHS (CDC) or USDA (APHIS) • CDC/APHIS inspection of lab

  29. Inventory Control • For Hazardous Agents • Know: • How much on hand • Where it is • Who has control of it • Inventory adjusted when purchased, used, transferred or destroyed. • Purchase or store only for active or soon to be active protocols

  30. Emergency Preparedness & Response • Plan coordinated with facility & outside officials (Fire, police etc.) • Specific to facility & agents in labs • Incorporate OSHA, VHA & research requirements • Vulnerability assessments & drills annually • Document all activities

  31. Training Requirements • Integrate Biosafety & Security • Applicable regulation (VA, OSHA, CDC) • Must occur prior to assignments • Annual refresher • Generic training • Specific to laboratory & agents • Maintain good records

  32. Required Policies and Procedures • Safety plan • Security plan • Physical • Personnel & Access • Cyber • Inventory control • Emergency planning & response • Training

  33. Policies & Procedures • Written & updated as required • Implementation must occur • Documentation

  34. REVIEW: Control of Hazardous Agents: Specific Requirements 1. Controlling lab access 2. Physical security 3. Registering labs for select agent or toxin use 4. Inventory control 5. Emergency preparedness 6. Training 7. Policies and procedures/plans

  35. Other New Issues • BSL-3 Laboratories • Annual Safety & Security visits by ORO • IG remains interested in BSL-3 security • Pans for new or decommissioning BSL-3: call ORD • Select Agents or Toxins • Final rule may be out in November • No major changes expected • New SA or Toxin use: report to CO • Exempt Quantities of Toxins

  36. Exempt Quantities of Toxins • Remain under tight security • Prevent misuse or theft • If not in sight or use must be locked up • Accurate inventory • Acquisition, transfer, destruction similar to SA & toxins • Possess only for specific protocol

  37. Submitting Biosafety Forms:VA Form 10-0398 • Required for SRS review • Just-in-time document for protocols submitted to CO • Problems found: • Not filled out completely • Missing required signatures • Information in form does not match protocol • Avoid HOLDS!

  38. Requesting Waivers • Waivers only if referenced in VHA policy • Rarely given for BSL-3 or SA and toxin lab requirements • Request sent to ORD • Required information: Directive 2002-075, Appendix B. • Call or e-mail if any questions

  39. Remember! • Directive 2002-075 as published in November 2002 is still the official policy • Information on slides may change once the new draft of this Directive is signed by the Under Secretary for Health • Please contact ORD for questions & help • Brenda Cuccherini, Ph.D. (202)254-0277 • brenda.cuccherini@hq.med.va.gov

  40. Why we are here!

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