Part 2: Internal and external emergency plans – do they exist and, if so, what are they for?

An attempt at clarification in two steps: In the last AGCT-Gentechnik.report, we discussed the external emergency plan; today, we discuss the internal emergency plan. An internal emergency plan is neither legally defined nor explicitly required by law. It is only indirectly required by the fact that, among other things, "emergency plans and information on measures to prevent accidents and operational disruptions" are required as information for the approval procedure under Section 10, Paragraph 2, No. 7 of the GenTG. Similarly, Section 21 Paragraph 3 Sentence 2 GenTG indirectly regulates that "the operator must immediately notify the authority responsible for notification, registration, granting of approval and monitoring of any incident that does not correspond to the expected course of the genetic engineering work or the release or placing on the market and where there is a suspicion of a threat to the legal interests referred to in Section 1 No. 1. All information necessary for the safety assessment as well as planned or implemented emergency measures must be reported. Since this also covers "planned" emergency measures, there is much to be said for an internal emergency plan. This is not provided for in Form AZ S1 when notifying an S1 facility. The internal emergency plan is only mandatory from S2 onwards via Form AL (information on safety measures in the laboratory area) and accordingly in AP (information on safety measures in the production area), AG (information on safety measures in greenhouses and climate chambers) and AT (information on safety measures in the animal husbandry area), each in Section 4.3. There is no specific form for this. The internal emergency plan is usually integrated into the operating instructions, for example, in the section on leaks or spills of biological material. These often contain information on how to collect and dispose of spilled material, how to clean up the area, and how to protect yourself. Furthermore, it is often stipulated that if further complaints arise, the occupational physician or accident and emergency department must be consulted immediately. There are also regulations stating that every accident must be reported to the laboratory manager so that he or she can inform the Health and Safety Office on the "Accident Report" form. These internal emergency measures must then be explained during the annual briefing.