New: Reference to the type of genetic engineering work in animal husbandry
Dr. Petra Kauch
Unclear change in the labelling of animal housing rooms security level 2 according to the GenTSV
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The regulation for marking an animal holding room security level 2 has changed as of March 1, 2021.
According to the old GenTSV (Annex V. II. Level 2 No. 3), the following was provided: *"If infected animals are present in the animal holding room, the door must remain closed. It must be marked with a notice indicating the nature of the work." *
This regulation is now contained in amended form in Annex 4 II. Security Level 2 b. Organizational Measures No. 4 GenTSV. It reads as follows: "No other animals should be kept in animal rooms where infected animals are housed, unless cross-contamination is not possible, such as when using special isolation systems. The doors must be marked with a notice indicating the nature of the genetic engineering work."
While the simple labeling "animal husbandry" or "animal experiments" was sufficient in the original version, this is no longer likely to apply under the new version. The legal justification for amending the GenTSV does not provide any detailed justification for the reformulation. It simply states that the associated (ed. note: old) regulations are similar sub-regulations in terms of content, but not necessarily identical in content due to adaptation to the state of science and technology, which does not really help with interpretation. This cannot mean that the complete risk assessment for genetic engineering work must be included there in the form of a note. A brief note based on the title of the work can be understood as such. In any case, the labeling alone with "genetic engineering facility, safety level 2" and "animal husbandry" is not sufficient.
It remains to be seen what requirements the regulatory authorities will impose regarding the signage of the facilities in the near future. To be on the safe side, it should be noted that a missing sign cannot result in a fine, as there is no corresponding offense under No. 4.