Use of Select Agents and Potentially Hazardous Biological Materials Policy

Policy Summary

Any research-related activity at The George Washington University ("GW" or "university") involving Select Agents, Potentially Hazardous Biological Materials, or conducting life sciences Dual Use Research of Concern (DURC) requires prior review and approval by the Institutional Biosafety Committee (IBC). Activity involving Select Agents (other than exempt quantities of listed Toxins) also requires express written permission from the Associate Provost for Research Integrity and Compliance. All IBC-approved activities involving Select Agents or Pathogens must be conducted in accordance with this policy. Failure to comply with this policy may result in disciplinary action up to and including termination.

Related Regulations

• Federal Select Agents and Toxins List
• CDC/NIH Biosafety in Microbiological and Biomedical Laboratories 
• OSHA: Occupational Exposure to Hazardous Chemicals in Laboratories, 29 CFR §1910.1450 
• Select Agent Regulations (Centers for Disease Control), 42 CFR Part 73 
• USA PATRIOT Act of 2001, P.L. 107-56 
• Select Agent Regulations (Department of Agriculture): 7 CFR Part 331 and 9 CFR Part 121

Who is Governed by this Policy 

• Students
• Staff
• Faculty
• Non-university entities using university property, equipment, or facilities

Policy

Prior Approval 

Anyone proposing to engage in an activity involving a Potentially Hazardous Biological Material must first check the Select Agent/ Toxin List and the Centers for Disease Control (CDC) / National Institutes of Health (NIH) publication Biosafety in Microbiological and Biomedical Laboratories to determine if the Agent or Toxin is a Select Agent or Pathogen.

Prior to obtaining Pathogens or Select Agents, storage and use must be reviewed and approved by the IBC. To obtain a review, complete and submit an IBC application to the Office of Research Safety (ORS). The IBC application must contain a summary of the proposed research and a written protocol detailing the specific steps for material handling in the laboratory or animal facility. The protocol must address all hazards posed by the Select Agents or Potentially Hazardous Biological Materials to be used. 

If the proposed work will include Select Agents, there are additional requirements that will need to be met before approval will be granted. Requirements for approval include registration, background checks, and written research protocols that address biosafety and containment, security, and incident response. Contact the Biosafety Officer within ORS to initiate the review process. Proposed use of materials deemed to be exempt under the regulations due to low quantities still must be reviewed and approved by the IBC prior to engaging in the activity to confirm safety measures are in place and that the use is truly exempt. Note also that any Select Agent discovered in any patient or other specimen must be reported to ORS immediately.

Since Select Agents pose a risk under Occupational Health and Safety Administration (OSHA) regulations, the Associate Provost for Research Integrity and Compliance needs to be informed about their use and storage on campus. The Associate Provost for Research Integrity and Compliance will notify other GW offices, as appropriate and other institutional approvals will be obtained as required. Once approval from the IBC involving the use of Select Agents is obtained, ORS will notify Environmental Health & Safety of the intended use. 

An individual who willfully or negligently violates this policy, federal, or state rules and regulations governing the use of Select Agents or Potentially Hazardous Biological Materials may have their approval and/or privileges to conduct research suspended or revoked pending review by the IBC, Associate Vice Provost for Research Integrity and Compliance, and any other institutional officials as appropriate. 

Usage 

Those working with Select Agents or Potentially Hazardous Biological Materials first must complete biosafety training and must read and comply with the university’s Biosafety Manual. Workers also must comply with all written protocols required by the IBC, all government regulations, and must cooperate in periodic reviews by the IBC. The IBC can at any time make changes to the requirements for the material. 

If the activity also involves recombinant DNA, review and approval are required in accordance with the Use of Recombinant DNA (rDNA) Policy.

Storage, Disposal, and Transfer

Storage and disposal of Select Agents or Potentially Hazardous Biological Materials must comply with the Biosafety Manual and the conditions of the IBC approval. All storage, disposal, or transfer of select agents must comply with federal law and the conditions of its registration. In the event of transferring Potentially Hazardous Biological Materials off campus, contact the Biosafety Officer for requirements on transfer and shipping. If the transfer will be to another country or to a foreign national, contact the GW Office of Research Security. Export Control regulations and considerations may apply. 

Definitions

Agents: Substance, whether biological or chemical, capable of producing an effect or reaction in living matter. An agent that is “infectious” is one that has the potential to produce disease. 

Potentially Hazardous Biological Materials: Infectious agents, human and non-human primate materials (including established cell lines), toxins of biological origin, regulated carcignogens, chemotherapy drugs, select agents, recombinant and synthetic nucleic acid molecules.

Pathogens: Those infectious agents identified by the CDC or NIH as having a biosafety level (BSL) of 2 or higher due to their ability to cause disease in healthy human adults. 

Select Agents: Pathogens (including genetically altered forms) or Toxins deemed by the CDC or U.S. Department of Agriculture to pose a high risk to human, animal, or plant health and could be utilized for terrorist activity. Also included are nucleic acids from these agents that could produce an infectious form or code for a toxin. The lists are incorporated in 42 CFR §73, 7 CFR §331 and 9 CFR §121 but a complete list can be found here. 

Toxins: Poisonous compounds produced by certain microorganisms, plants, or animals that produce disease. 

Procedures

Further information and guidelines regarding Select Agents and Pathogens, and regarding IBC guidance and forms, is available on the ORS website and the university’s Biosafety Manual.

Related Information

• GW Institutional Biosafety Committee (IBC) 
• Select Agents/Toxin List
• Use of Recombinant DNA (rDNA) Policy
• Chemical Hygiene and Communications Policy
• Export Control Policy 
• Hazardous Waste Management Policy 
• Personal Protective Equipment Policy
• www.selectagents.gov

Contacts