Do you have to have been a PL*in in an S2 facility to become a PL*in in an S3 or S4 facility?

This question is not easy to answer, as the requirements for expertise according to Section 28 Para. 2 No. 2 GenTSV have changed with the amendment to the GenTSV (2019). Accordingly, in practice, it is often believed that one must already have at least two years of experience as a PL*in within the framework of safety levels 2, 3 or 4 in order to be able to become a PL*in in an S3 or S4 facility. However, if one reads Section 28 Para. 2 No. 2 GenTSV carefully, one will find that it only describes the requirements for expertise if one is aiming for a project management position. Applicants for the S3 facility must have at least three years of experience in the field of genetic engineering, in particular microbiology, cell biology, virology or molecular biology. In addition, for the desired project management position for genetic engineering work at safety level 3 or 4, it is required that "at least two years of experience within safety levels 2, 3, or 4" be present. According to the clear wording, this requirement refers only to work within these safety levels, not to the position as a PL*in. Therefore, proof of at least two years of experience with S2 work is sufficient to become a PL*in in an S3 or S4 facility. According to the wording, it is not necessary to have previously held the position as a PL*in.