Employees in BSL3 laboratories or S3 laboratories according to GenTG – what a difference!

Since the GenTSV and the BioStoffV, along with TRBA 200, contain different requirements regarding the demands placed on employees, a closer look is worthwhile. This is particularly important with regard to the employment of interns, students, and pupils in the corresponding facilities. Since this discussion exceeds the length of a single AGCT-Gentechnik. report text, it is discussed in this AGCT-Gentechnik. report . for the GenTSV and hereinafter AGCT-Gentechnik. report for the BioStoffV and TRBA 200.

The GenTSV:

The GenTSV does not contain any specifications for the requirements for employees in S3 facilities. The specifications of Section 27 GenTSV, i.e. the expert knowledge requirements, refer only to project managers (PL) and biological safety officers (BBS). This means that for other employees in an S3 facility no special requirements for expertise be done, i.e. no expertise is required.

Regulations in Section 17, Paragraph 4, Sentence 1, and Section 27, Paragraph 1, No. 5 of the Genetic Engineering Ordinance (GenTSV) only indirectly contain these provisions. According to Section 17, Paragraph 4, Sentence 1 of the Genetic Engineering Ordinance, employees may only be commissioned to perform genetic engineering work if they are sufficiently qualified and instructed. No further details are given as to when this is the case. According to Section 27, Paragraph 1, No. 5 of the Genetic Engineering Ordinance, the PL is responsible for ensuring that employees are adequately qualified and instructed. This means that the only requirement for those commissioned to perform genetic engineering work is sufficient qualification and instruction by the PL or a person appointed by the PL.

Result : Apprentices, interns and students can also be employed in genetic engineering work if they have sufficient qualifications and training in S3 facilities.