3-2 biosafety risk management

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    BIOSAFETY RISKMANAGEMENT

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    Design and operation of a bioprocessing facility

    must assure safety of personnel within the facility

    and those in the surrounding community

    Protection is achieved through a combination of

    engineered facilities, processes, and equipment

    worker training and education

    use of personnel protective equipment

    operational practices

    validation of machinery and methodologies controlled access to facilities

    biosafety committee or subcommittee

    medical and environmental surveillance

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    Activities involving LMO are regulated by the

    Biosafety Act 2007and Biosafety Regulations

    2010, to ensure safe application of

    biotechnology in a responsible and orderly

    manner.

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    BIOSAFETY LEVELS (BSL) FOR

    CONTAINMENT

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    Biosafety containment of the LMO activity is

    achieved with a combination of facility design,

    administrative controls, engineering controls or

    use of Personal Protective Equipment (PPE).

    There are four BSL for containment based on

    existing international approaches to

    pathogenic organisms:

    Biosafety Level 1 (BSL1)

    Biosafety Level 2 (BSL2)

    Biosafety Level 3 (BSL3)

    Biosafety Level 4 (BSL4)

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    For genetic modification activities, five

    categories of containment facility are:

    Genetic Modification of Microorganisms (GM-BSL)

    Genetic Modification of Plants (GP-BSL)

    Genetic Modification of Animals (GA-BSL)

    Genetic Modification of Arthropods (GI-BSL)

    Genetic Modification of Aquatic Organisms (GF-BSL)

    The genetic modification BSL dictates theminimum level of containment required for

    carrying out activities with LMO and related

    materials originating from these organisms.

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    If researchers are unsure about the

    containment level required for their research

    and development activities, they should

    consult their respective Institutional Biosafety

    Committees (IBC).

    The containment requirements for work with

    genetically modified (GM) microorganisms are

    also the fundamental requirement forcontainment involving plants, animals,

    arthropods and other aquatic organisms.

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    BIOSAFETY LEVEL

    GUIDELINE

    LaboratoryFacilities

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    Biosafety Level 1 (BSL-1)

    Risk Group 1

    Low individual and community risk (BSL1 )

    Pathogenity Features

    A microorganism that is unlikely to cause human

    disease or animal disease.

    Agents include Bacillus subtilis,non-pathogenic E. colispecies

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    BSL1-General

    A laboratory classified as GM-BSL1 is appropriate for

    conducting activities of no known or minimal

    potential hazard to laboratory personnel,

    community and environment as listed below:

    Research involving the introduction of naked

    nucleic acids into RG 1 microorganisms

    Experiments with LMO microorganisms and

    materials originating from these organisms Experiments involving approved host/vector

    systems provided

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    BSL1-Laboratory Facility

    a) The laboratory is not separated from the generaltraffic patterns in the building

    b) The laboratory is designed with open bencheswhich can be cleaned easily

    c) Bench tops should be impervious to water andresistant to acids, alkali, organic solvents and

    moderate heat

    d) Laboratory furniture should be sturdy. Spacebetween benches, cabinets and equipment areaccessible for cleaning

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    BSL1-Laboratory Facility

    e) Entrances to the laboratory should be posted with an

    appropriate signage identifying the type of laboratory

    facility and listing the procedures applicable, including

    emergency and maintenance procedures. The contact

    information of the laboratory supervisor or other

    responsible persons should be listed

    f) Each laboratory should contain a sink for hand-washing

    g) The laboratory may be equipped with fumehood

    h) There should be access to a steam steriliser/autoclave

    in the same building

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    BSL1-Work Practices

    a) Laboratory personnel working in a GM-BSL1 laboratory

    should be supervised by a scientist with general training

    in microbiology, molecular biology or a related science.

    b) Laboratory coats should be worn during work and

    removed before leaving the laboratory premises. Personnel

    may be required to change into footwear specified for the

    laboratory. Gloves should be worn when handling LMO

    and material originated from these organisms.

    c) All persons handling LMO and materials originated from

    these organisms should wash their hands after removing

    gloves and before leaving the laboratory.

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    BSL1-Work Practices

    d) Protective eye wear should be worn for anticipatedsplashes of microorganisms or other hazardousmaterials to the face.

    e) All cultures should be clearly labelled and acentral logbook kept in the laboratory.

    f) When experiments are in progress, access to thelaboratory should be limited at the discretion of the

    Laboratory Supervisor.

    g) Work surfaces should be decontaminated regularlyand immediately after any spill of viable material.

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    BSL1-Work Practices

    h) All contaminated liquid or solid wastes should bedecontaminated before disposal.

    i) Mechanical pipetting devices should be used,mouth pipetting is prohibited.

    j) All procedures, involving liquids, are performedcarefully to minimise the creation of aerosols.

    k) Eating, drinking, smoking, handling contactlenses and applying cosmetics is prohibited inlaboratories.

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    BSL1-Work Practices

    l) Food or drinks for personal consumption should

    not be brought into the laboratory or stored in

    laboratory refrigerators.

    m) An insect and rodent control programme should

    be implemented.

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    The minimum PPE required for the BSL-1 laboratory

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    Biosafety Level 2 (BSL-2)

    Risk Group 2

    Moderate individual risk, limited community, livestockor environment risk (BSL2)

    Pathogenicity Features

    A pathogen that can cause human or animal disease butis unlikely to be a serious hazard to laboratory workers,the community, livestock or the environment

    Laboratory exposure may cause serious infection.Infectious risk is via direct contact, ingestion or

    inhalation. Effective treatment, preventive and control measures are

    readily available and can be implemented to controldisease transmission.

    Risk of spread to a community is limited.

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    Biosafety Level 2 (BSL-2)

    Agents associated with human disease

    Generally required for working with any human-derived blood, bodily fluids, tissues in which

    infectious agent may be unknown

    Agents include measles virus,

    Salmonellaspecies, pathogenicToxoplasma, Clostridiumbotulinum, hepatitis B virus

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    BSL2-General

    A laboratory classified as GM-BSL2 is

    appropriate for conducting activities that has

    moderate potential hazard to personnel,

    community and the environment listed

    below: Research involving the introduction of naked nucleic

    acids into RG 2 microorganisms

    Experiments with LMO and related materials,

    harboring DNA from a RG 2 microorganism.

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    BSL2-Laboratory Facility

    In addition to the facility design features specified for

    BSL1, following additional features are essential:

    a) A hazard warning sign incorporating the universal

    biohazard symbol and the level of containmenttogether with access restrictions should be displayed

    on the access door to the laboratory work area.

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    BSL2-Laboratory Facility

    Example ofbiosafety signposted outside lab

    working withinfectious agents

    Labs biosafety level

    Infectious agents

    under study

    Contact informationfor responsible personand 2 emergency

    contacts

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    BSL2-Laboratory Facility

    b) The ceilings, walls and floors of the laboratory

    should be smooth, easy to clean, impermeable to

    liquids, and resistant to commonly used reagents

    and disinfectants.

    c) A dedicated hand basin of the hands-free

    operation type should be provided within each

    laboratory, near each exit.

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    BSL2-Laboratory Facility

    Hand basin facility

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    BSL2-Laboratory Facility

    d) Windows in the laboratory should be closed and sealed.

    e) An autoclave should be located within the building.

    Autoclaves should be certified annually by the Departmentof Occupational Safety and Health/DOSH.

    f) Freezers, refrigerators or other storage units used for

    BSL2 microorganisms located outside the designated

    laboratory should be posted with the appropriate signage.

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    BSL2-Laboratory ventilation

    The laboratory should be well ventilated.

    If required an inward flow of air should be

    maintained by extracting room air using

    mechanical ventilation to ensure directional

    airflow.

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    BSL2-Work Practices

    In addition to the work practices described in BSL1, the

    following work practices should be observed:

    a) The Laboratory Supervisor establishes policies and

    procedures whereby access is restricted to persons whohave been advised of the potential hazard and who meet

    specific entry requirements (e.g. immunisation).

    b) Laboratory personnel should receive appropriate

    training on the potential hazards associated with the workinvolved and the necessary precautions to preventexposures. Personnel should receive annual updates, or

    additional training as necessary for procedural or policy

    changes.

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    BSL2-Work Practices

    c) Procedures which produce infectious aerosols

    should be conducted in biological safety cabinets or

    other physical containment equipment.

    d) Experiments of lesser biohazard potential can becarried out concurrently in carefully demarcated

    areas of the same laboratory.

    e) An institutional biosafety manual is prepared oradopted for use in the laboratories. Personnel are

    advised on special hazards and are required to read

    and follow the instructions on practices and

    procedures.

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    BSL2-Work Practices

    f) Goggles, mask or face shield should be used for

    anticipated splashes or sprays of infectious LMO and

    materials originated from these materials to the face,

    when handling microorganism outside the biological

    safety cabinet.

    g) Respiratory protection should be worn when

    aerosols cannot be safely contained.

    h) All solid wastes from GM-BSL2 laboratories,

    including infectious waste should be decontaminated

    by autoclaving for at least 30 minutes at a pressure

    of 15 psi and 121oC.

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    BSL2-Work Practices

    i) Liquid wastes generated during BSL2 activities are to bedecontaminated immediately by mixing with a suitabledisinfectant

    j) Extreme caution should be observed when handlingneedles and syringes to avoid accidental needle-stickinjury and generation of aerosols during use and disposal.

    k) Spills and accidents that may cause over-exposure toLMO and materials originating from these organismsshould be immediately reported to the LaboratorySupervisor and the IBC

    l) A record book should be maintained to provide an up-to-date inventory of the procedures performed.

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    Biosafety Level 3 (BSL-3)

    Risk Group 3

    High individual, low community risk

    Pathogenicity Features

    Organism, which may be an exotic or indigenous

    agent with potential to transmit disease mainly via

    aerosols. Disease caused is severe and may result in

    death. It could present a risk if spread in thecommunity however effective treatment, preventive

    and control measures are available

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    Biosafety Level 3 (BSL-3)

    Agents include Mycobacteriumtuberculosis,St. Louis encephalitisvirus, Francisella tularensis,Coxiella burnetii

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    BSL3-General

    A laboratory classified as BSL3 is appropriate for

    conducting activitiesthat has moderate potential

    hazard to personnel, community and the

    environment listed below:

    Research involving the introduction of naked

    nucleic acids into RG 3 microorganisms

    Experiments with LMO and related materials,

    harboring DNA from a RG 3 microorganism

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    BSL3- Laboratory Facility

    The design, construction and major changes to the

    GM-BSL3 facility should be certified by a

    competent authority/organisation endorsed by the

    NBB before commencement of work.

    In addition to the facility design features specifiedfor BSL1 and BSL2, following additional features

    are essential:

    a) The laboratory should be physically separated

    from other areas including offices used by laboratory

    personnel and is not accessible by the general

    public.

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    BSL3- Laboratory Facility

    b) Physical separation of the high containment

    laboratory from access corridors or other laboratories

    or activities is achieved by a double door system

    where entry to the laboratory facility is gainedthrough an airlock.

    c) The laboratory and airlock should be sealable to

    permit safe decontamination with gases.

    d) All room penetrations should be sealed to ensure

    they are air tight

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    BSL3- Laboratory Facility

    e) Access doors to the laboratory or containment

    module should be self-closing and open outwards.

    f) One side of the laboratory wall should have a glasspanel or observation window to view laboratory

    occupants from the outside.

    g) An autoclave for decontaminating laboratory wasteshould be available within the laboratory, preferably

    located within the barrier wall of the GM-BSL3

    laboratory, but not situated in the airlock.

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    BSL3- Laboratory Facility

    h) Liquid effluents should be discharged in a mannerappropriate to the type of waste.

    i) A telephone and fax machine or other means of outside

    communication should be provided inside the laboratoryunit.

    j) An audible emergency alarm should be provided withinthe laboratory to indicate a loss of negative pressure and a

    visible alarm is provided outside the laboratory to indicatethe same.

    k) The BSL3 facility should be tested and certifiedannually at least every 12 months.

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    BSL3- Laboratory ventilation

    The laboratory ventilation should incorporate thefollowing features:

    a) A ducted exhaust air-ventilation system is

    provided

    b) Air supply and exhaust from Class II biologicalsafety cabinets should be connected in a mannerthat avoids any interference with the air balance of

    the cabinets or buildings exhaust system.

    c) The proper directional airflow into the laboratory isverified by airflow tests.

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    Wash hands

    after removing

    PPE at the

    hands-free sink

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    Eye/face wash: understand how to use, flush at

    least weekly, and identify closest station outside the

    BSL-3 lab (in event of release outside ofcontainment)

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    BSL3- Work Practices

    In addition to the work practices described in BSL1

    and BSL2, the following work practices should be

    observed:

    a) The laboratory senior management is required toestablish policies and procedures whereby access to

    the laboratory is restricted to authorised persons

    who have been advised of the biohazard and who

    meet any medical requirements.

    b) All personnel should have specific training in

    handling pathogenic organisms and in the use of

    safety equipment and controls.

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    BSL3- Work Practices

    c) The laboratory door should be locked when the

    room is unoccupied.

    d) If experiments involving other organisms thatrequire lower levels of containment are to be

    conducted in the same laboratory concurrently with

    work requiring BSL3 level physical containment,

    such experiments should be conducted in

    accordance with all BSL3 level practices.

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    BSL3- Work Practices

    e) Work surfaces of biological safety cabinets andother containment equipment should bedecontaminated

    f) PPE that protects street clothing (e.g. tyvex suitand boots). In addition, appropriate respiratoryprotection should be made available.

    g) Liquid wastes generated during BSL3 activitiesshould be decontaminated immediately with suitabledisinfectant. All solid wastes are decontaminated byautoclaving before disposal for incineration by agovernment authorised service provider

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    BSL3- Work Practices

    i) A medical surveillance programme should be

    instituted for all persons entering a BSL3 facility

    j) An Emergency Response Plan should bedocumented and personnel should be trained in

    these procedures which include spill management,

    emergency evacuation if necessary, as well as

    incident reporting system.

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    Biosafety Level 4 (BSL-4)

    Risk Group 4

    High individual and community risk (BSL4)

    Pathogenicity Features

    Organism, which may be an exotic agent or new

    agent usually able to cause life-threatening human

    disease. The infectious disease is readily

    transmissible from one individual to another.

    Infectious disease may be transmitted via aerosol orvia an unknown route. Effective treatment,

    preventive and control measures are not readily

    available.

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    Biosafety Level 4 (BSL-4)

    Agents (all viruses) include

    Marburg virus, Ebola virus,viruses that cause Congo-Crimean hemorrhagic fever,Lassa fever

    (transmission electron micrograph

    of Ebola virus)

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    BSL4-General

    A laboratory classified as BSL2 is appropriate

    for conducting activities that may cause

    serious harm to the laboratory personnel,

    community and environment if accidentally

    released listed below:

    Research involving the introduction of naked nucleic

    acids into RG 4 or exotic agents

    Experiments with LMO and related materials,harboring DNA from a RG 4 microorganism

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    BSL4- Laboratory Facility

    The design, construction and major changes to the BSL4

    facility should be certified by a competent

    authority/organisation endorsed by the NBB before

    commencement of work.

    In addition to the facility design features specified for

    BSL1, BSL2 and BSL3 the following additional features

    are essential:

    a) A BSL4 facility is housed in a separate building. Anouter and inner change-room separated by a walk-throughdouble door shower airlock should be provided for

    personnel entering and leaving the facility. The outer door

    of the facility should be lockable.

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    BSL4- Laboratory Facility

    b) Fumigation chamber or ventilated air-lock is

    provided for passage of materials, supplies or

    equipment that is not brought into the facility

    through the change room.

    c) As much valve and control equipment as possible

    should be located outside the laboratory boundary to

    minimise the need for service personnel to enter the

    laboratory.

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    BSL4- Laboratory Facility

    d) Walls, floors and ceilings of the facility should beconstructed to form a sealed internal shell that facilitatesfumigation and is animal and insect-proof. The internalsurfaces of this shell should be resistant to liquids and

    chemicals, thus facilitating cleaning and decontaminationof the area. All penetrations in these structures andsurfaces should be sealed.

    e) If there is a central vacuum system, it should not serveareas outside the facility. In-line HEPA filters should be

    placed as near as practicable to each point of use. Filtersare installed to permit in-place decontamination andreplacement. Other liquid and gas services to the facilityare protected by devices that prevent backflow.

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    BSL4- Laboratory Facility

    f) A double-door autoclave is provided fordecontaminating materials from the facility and fromthe inner clothing change room.

    g) A pass through dunk tank or decontaminationchamber should be provided so that materials thatcannot be autoclaved can be rendered safe forremoval from the facility.

    h) An automatic changeover emergency powersource, emergency lighting and communicationsystem should be provided to ensure continuingoperation of the ventilation systems, biological safetycabinets, room access and controls.

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    BSL4- Laboratory Facility

    i) For certain requirements,

    i) A specially designed suit area may be provided

    within the facility.

    ii) Personnel who enter this area should wear a one-piece positive pressure suit that is ventilated by a

    life support system that includes an alarm and

    emergency back-up breathing air system.

    iii) Entry should be via an airlock fitted with a personal

    body shower into an anteroom leading to a secondairlock fitted with a chemical disinfectant shower

    provided to decontaminate the surface of the suit

    before the personnel leaves the area.

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    BSL4- Laboratory Facility

    i) A double door autoclave with doors at each end isprovided for decontaminating waste materials to beremoved from the suit area.

    ii) An air supply for connection to the positivepressure suit should be provided in the anteroom.

    iii) The exhaust air should be filtered through two setsof HEPA filters installed in series.

    iv) The air pressure within the suit area should belower than that of the adjacent entry, exit and non-suit areas.

    v) A duplicate ventilation system, exhaust fan and anautomatically-starting emergency power sourceshould be provided to automatically re-establishlaboratory ventilation and pressure conditions inevent of equipment failure.

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    BSL4- Laboratory Ventilation

    The laboratory ventilation should have thefollowing features:

    a) A separate supply and exhaust non re-circulating

    air ventilation system should be provided.

    b) Both supply and exhaust air should be filteredthrough HEPA filters.

    c) The filtered air from Class III biological safetycabinets is discharged through the facility exhaustsystem in a manner that avoids any interference withthe air balance of the cabinets or the facility exhaustair system.

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    BSL4- Laboratory Ventilation

    d) The ventilation control system should raise an

    audible alarm within the laboratory and at an

    attended location when room differential air

    pressures depart from set points.

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    BSL4-Work Practices

    In addition to the work practices described in BSL1,BSL2 and BSL3, the following work practices should

    be observed:

    a) Accessibility is managed by the LaboratorySupervisor, Biological Safety Officer (BSO) or other

    persons responsible for the physical security of the

    facility.

    b) A facility operations manual and SOP should be

    prepared by the management. Practical and effective

    protocols for emergency situations should be

    documented in the SOP.

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    BSL4-Work Practices

    c) Authorised persons should comply with the

    instructions and all other applicable entry and exit

    procedures in the manual and SOP

    d) All personnel should be trained in the specific

    working aspects of the containment laboratory,

    including handling of the relevant pathogens, clean-

    up of infectious spills and use of safety equipment.

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    BSL4-Work Practices

    e) A risk assessment of the working environment

    should be undertaken by management, taking into

    consideration all matters influencing the safety of

    personnel.

    f) Personnel should enter and leave the facility

    through the clothing change and shower rooms,

    except in cases of emergency, for example fire or

    explosion inside the containment laboratory,

    personnel can use the air-locks to leave the

    laboratory.

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    BSL4-Work Practices

    g) Supplies, materials and specimens should only be

    brought into the facility through the change and

    shower rooms, the double-door pressure steam

    steriliser, the fumigation chamber, the airlock or thedunk tank.

    h) A primary container holding viable or intact

    biological material should only be opened in the

    maximum containment laboratory.

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    BSL4-Work Practices

    i) No material should be removed from GM-BSL4

    laboratory unless it has been autoclaved or

    decontaminated..

    j) RG 4 biological materials should be stored only within

    the facility. If RG 4 biological materials are to be removed

    from the maximum containment laboratory in a viable or

    intact state, they should be transferred in a non-

    breakable, sealed primary container, and then enclosed ina non-breakable, sealed secondary container, which isremoved from the facility through a disinfectant dunk

    tank, fumigation chamber or an air-lock designed for this

    purpose.

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    BSL4-Work Practices

    k) All practices within the facility involving agents

    assigned to RG 4 should be conducted in Class III

    biological safety cabinets or alternatively Class II

    biological safety cabinets used in conjunction withone-piece positive pressure personnel suits

    ventilated by a life-support system.

    l) Precautions should always be taken with any

    contaminated sharp items including needles andsyringes, slides, pipettes, capillary tubes and

    scalpels..

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    BSL4-Work Practices

    m) A system should be set up for reporting accidents

    and exposures to microorganisms and for the

    medical surveillance of illnesses that are potentially

    laboratory associated.

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    Scientists working in a BSL-4

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    BL4 Lab - Max

    Containment

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    Containment Levelof Laboratories

    CL1:-Ill just do it on the bench over there..

    CL2:-OK, so Ill have to use the hood.

    CL3:-Thats that room along the corridor that no-

    one goes in? CL4:-Spacesuits?

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    BIOSAFETY CABINET

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    Biosafety Cabinet

    Biological safety cabinets are the primary

    means of containment in process support

    laboratories and during early stages of culture

    development Based on design and the protection afforded,

    biological safety cabinets are designated as

    Class I, II, and III

    Must be properly maintained and regularlyserviced

    Must be certified annually and when new,

    moved, or repaired

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    Biosafety Cabinet

    Must be used in conjunction with goodmicrobiological techniques

    Provide protection for personnel, product, and

    environment

    The cabinets should be decontaminated withformaldehyde gas or an equivalent disinfectant

    before testing when there have been used for

    handling RG 2, 3 or 4 microorganisms.

    Penetration of the decontaminants throughoutall the sections of the cabinets is essential.

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    BSC Class I

    A Class I cabinet is a ventilated cabinet for

    personnel protection.

    Air flows inward, away from the operator.

    The exhaust air from this cabinet filters through aHigh Efficiency Particulate Air (HEPA) filter.

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    This cabinet is used in three operational models:

    i. with full-width open front

    ii. with an installed front-closures panel (having

    four 12-cm diameter openings) without gloves

    iii. with an installed front-closure panel equippedwith arm-length rubber gloves.

    The face velocity of the inward flow of air through

    the full-width open front is 30 m per minute or

    greater.

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    BSC Class I

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    BSC Class II

    A Class II cabinet is a ventilated cabinet for

    personnel and product protection.

    It has an open front with inward airflow for

    personnel protection and HEPA filtered massairflow for product protection.

    The cabinet exhaust air is filtered through a HEPA

    filter.

    The face velocity of the inward flow of air through

    the full-width open front is 30 m per minute or

    greater.

    l

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    BSC Class II

    While HEPA filters are effective for trappingparticulates and infectious agents, these filters will

    not capture volatile chemicals or gases

    As general, no BSC suited for handling volatile

    toxic substances

    l ( )

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    BSC Class II (A & B)

    SC Cl

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    BSC Class III

    A Class III cabinet is a closed-front ventilatedcabinet of gas-tight construction, which providesthe highest level of personnel protection amongbiological safety cabinets.

    The interior of the cabinet is protected fromcontaminants outside of the cabinet.

    The cabinet is fitted with arm-length rubber glovesand is operated under a negative pressure of atleast 1.25 cm water gauge.

    All air supply is filtered through HEPA filters.Exhaust air is filtered through two HEPA filtersbefore being discharged to the outsideenvironment.

    BSC Cl III

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    BSC Class III

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    HEPA FILTER

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    Control of airborne particulates in indoorenvironments is critical to develop quality

    products, protect employees from contact with

    hazardous materials, or prevent health problems

    from prolonged exposure to allergens

    HEPA filters in biological safety cabinet

    particle sizes

    efficiency and penetration

    filter standards and performance testing

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    HEPA filter are rated to remove particles down to0.3micrometer with efficiency of 99.97%

    Filters are susceptible to shock-induced

    mechanical damage

    Biosafety cabinet must be certified after initialinstallation, after relocation, after repair and at

    yearly interval

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    The certification test depend on the type of cabinet Downflow velocity and volume testing (I and II)

    Inflow velocity test (I and II)

    Negative pressure testing (II and III)

    Air flow smoke pattern test (I and II) HEPA filter leak test (I-III)

    Cabinet leak test (II and III)

    Alarm and interlocks (III)

    BSC SUMMARY

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    BSC SUMMARY

    Biohazard

    level

    Protection provided Cabinet

    classPersonnel Product Environme

    ntBL1-3 Yes No Yes I

    BL1-3 Yes Yes Yes II

    BL4 Yes Yes Yes III

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    LAYOUT

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    The layout of the facility affects efficiency of operations

    the potential for containment

    prevention of cross-contamination

    Contained, clean, and dirty areas should beidentified on the process flow sheets and the

    building layout drawings

    Movement of personnel, equipment, process

    streams, and air across containment boundary

    must assure integrity of containment

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    Flows must be unidirectional (clean to dirty areas)-should not cross

    No back-tracking

    The biohazard containment areas and the aseptic

    product filling areas should be located in differentwings of the facility, with no sharing of common

    hallways or direct access

    Adequate space

    No overcrowded