Can a BBS still work as a PL on their own project in the lab?

Dr. Petra Kauch

On the question of reviewing the laboratory activities of the BBS in its own project

In small genetic engineering facilities, but also at universities, especially where there is no central biological safety officer (BBS), the question often arises as to whether a BBS can continue to manage its own project as a project manager in a genetic laboratory. In this regard, the Federal/State Working Group on Genetic Engineering (LAG-Gentechnik) has already stated in its collection of resolutions on Section 3 Nos. 7-9 GenTG p. 5 that the BBS cannot be the same as the project manager or operator. If the BBS were identical to the PL, this would be tantamount to self-review; if the BBS were identical to the operator, this would be self-advisory. For the above question, this means that the BBS cannot supervise its own project either. Nevertheless, the LAG-Gentechnik considers it permissible to commission the BBS to monitor the project manager even with regard to genetic engineering work in which the project manager participates (regarding Section 18 Para. 1 No. 1 GenTSV, LAG meeting of April 28-29, 1992 in Würzburg). This is questionable, since in this case, too, the BBS would have to monitor its own activities. Such self-monitoring of its own activities is not provided for in either the GenTG or the GenTSV. It would therefore be better to have the activities in which a BBS participated as project manager reviewed by another BBS, or possibly an external BBS, and to have the operator only receive external advice in this regard.

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