I would be fine with allowing a student to work with a BSL2 organism with proper training, controls, decontamination, etc. I would focus the training on the mode of transmission and remember that BSL2 is equivalent to OSHA’s BBP Standard, recommend focusing on the potential for contact transmission, effective decontamination (don’t forget the specific chemical, concentration and contact time), immediately reporting all accidents or the signs/symptoms of potential exposure remembering that staph can also be found in multiple forms, including MRSA. We all carry staph, it is normally found on the skin, in the nose, etc., but becomes a hazard when damage to the skin or a potential route of exposure is available. Margaret’s response was dead-on to ensure the student knows/understands what they are dealing with, how to properly respond to an incident and the potential risks. But, the relative risks can be reduced with proper engineering, administrative or PPE controls. The key is to teach the student the necessity and importance of the controls. After re-reading your original post, I am very comfortable with these recommendations considering that the student you are teaching properly could someday be working with organisms requiring a higher level of control. My opinion is to teach someone the right processes to implement/practice/apply using the lowest potential risk pathogen to the student while ensuring all requirements are met. Margaret, I would like to use/cite your response in the future if you don’t mind, well done.
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Margaret Rakas
Sent: Thursday, October 06, 2011 12:33 PM
Subject: Re: [DCHAS-L] Biosafety Level 2 bacteria use
We have had several labs work with BSL2 materials....
First, everyone involved in this project should be aware of the CDC's BMBL as an extremely useful resource, available at http://www.cdc.gov/biosafety/publications/bmbl5/. It will give you information regarding what the laboratory requirements are in terms of facilities and practices.
We have established an Institutional Biosafety Committee (IBC) whose mandate (from the College's president) is to review all research covered by the NIH Recombinant DNA guidelines, any infectious materials (so capture BSL2) and any materials covered under OSHA's Bloodborne Pathogen Standard. The Committee consists of several biology department members, two community representatives, and me (as Biosafety Officer). Before research with any materials/organisms which fall under one or more of these categories can begin, we require that the faculty supervisor prepare a protocol which details the experiment and the location(s) where all activities will take place (some instruments may not be in their lab, what work will be performed in a biosafety cabinet versus on the bench, etc). We are into specifics, so the disinfectant being used has to be named, the steps occuring must be described, etc. The faculty member presents the protocol and takes questions for about 10-15 minutes at the IBC meeting; we then go into closed session and typically require only a few edits. However, depending on the work proposed, we have suggested additional containment (the use of safety caps when centrifuging, for example) or other protocol modifications. The PI also has to write up a short biosafety manual, which states what PPE will be required, discusses the major routes of entry, how waste will be handled, and how chemical spills will be addressed. The idea behind all of this is that these are training documents for the student, so they understand what they are doing and why they can't do the work in another space or another manner (for example, it may be more convenient to vortex on the bench, but that is something our IBC has not permitted).
This approach works well for us; it provides security in knowing that students are properly trained and following procedures reviewed for safety and the research does 'get done'. Initially, faculty were afraid that if they switched buffer solutions or made some other small non-hazardous change they would have to go through this process again, but that is not how this committee operates--we're not on a 'witch hunt' to prevent research-- and after about 6 years of this process, we now have substantial credibility.
Depending on the structure and culture of your institution, this route may not work for you or your researchers.
I would say that training and supervision of the student(s) is extremely important....and I really like having the committee structure. The American Biosafety Association (ABSA, www.absa.org) has a listserv which I have found extremely useful for these sorts of issues....
>>> Ferm Barret A <FermBarretA**At_Symbol_Here**SAU.EDU> 10/6/2011 10:57 AM >>>
We have a push for undergrad research (at our primarily undergrad institution), and a student wants to work with a Level 2 organism (Staph. aureus) under the supervision of our cell biologist. This will be the first time a non-faculty member has worked directly with a level 2 organism here. Please share thoughts about whether this is/is not advisable, the relative risks, etc. Being the first time this has come up, we are in a position to formulate our policy. Many thanks.
Chemical Hygiene Officer
Biology & Chemistry Laboratory Coordinator
St. Ambrose University
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