Plastic recycling from S2 genetic engineering labs? (Part 3)

The Genetic Engineering Safety Ordinance (GenTSV) permits, under certain conditions, the disposal of plastic waste from S1 genetic engineering facilities without special pretreatment. The underlying aspects were already discussed in the January/February AGCT Genetic Engineering Report [insert link]. But what about waste from S2 genetic engineering facilities? Genetic engineering law is based on the paradigm that damage caused by genetically modified organisms must be minimized in terms of both the extent and probability of occurrence. However, potential damage and its consequences are difficult to predict, especially if GMOs were to leave the genetic engineering facility. The major "cut" in the assessment of possible damage, also with regard to waste pretreatment, therefore lies between safety levels S1 (no risk to human health or the environment) and S2 (low risk to human health or the environment). Section 24 of the GenTSV therefore provides exceptions to the generally required waste pretreatment, primarily for S1 facilities. However, even in S2-EDGE cell culture, plastic waste such as media containers and ready-to-use buffer solution bottles primarily arises in direct connection with genetic engineering work. This is because S2 GMOs are openly processed under the safety cabinet, especially because of the potential risk of contamination. A reference to an exception to waste pretreatment pursuant to Section 24, Sentence 2 of the GenTSV—"no direct connection with genetic engineering work"—is therefore out of the question. Section 24, Sentence 3 of the GenTSV does, however, specify further exceptions. But these explicitly only apply to waste from safety level 1 facilities. Therefore, according to Section 23 of the GenTSV, the following applies: "The operator must ensure that wastewater as well as liquid and solid waste from facilities in which genetic engineering work at safety level 1 or 2 is carried out... is pretreated in such a way that the genetically modified organisms they contain are inactivated to such an extent that no dangers... to humans or the environment... are to be expected." By definition, this can only be claimed for plastics from S2 work areas with prior inactivation. And the method of choice for this in the GenTSV is autoclaving.

Conclusion: Waste pretreatment by autoclaving is the norm from S2 onwards. Recycling of plastics from S2 facilities and genetic engineering facilities with even higher safety levels is still possible, but only after autoclaving. However, this would require the plastics to be collected as sorted as possible, autoclaved, and only then recycled. This, however, also requires the organizational conditions within the S2-EDGE facility to be created: that is, the space for sorting by type must be available, as well as the appropriate training for the personnel performing this work. Whether this effort is worthwhile depends not least on the volume of plastic fractions generated and the energy efficiency of the recycling process.