New fines for project management

It is now known that, with the amendment to the GenTSV (General Safety Regulations) effective March 1, 2021, electronic training in the S1 area can be provided, and this is partially practiced nationwide. This results from Section 17, Paragraph 4, Sentence No. 2 of the GenTSV. According to this, training at safety levels 2, 3, or 4 must be conducted verbally; at safety level 1, training must be conducted verbally or via electronic communication media with a performance review, and in each case, job-specifically, before the first assignment, and thereafter at least once a year.

In parallel, a corresponding fine has been introduced in Section 33 No. 8 of the GenTSV. According to this, violations of Section 17 Paragraph 4, Sentences 1 or 2 of the GenTSV are subject to fines if employees are not instructed, are not instructed correctly, are not incompletely instructed, are not in the prescribed manner, or are not in a timely manner. Aside from the fact that this list lists numerous errors in instruction as subject to fines, this is also tricky because it also covers instruction "in a manner not prescribed." Extreme caution is required here , as the regulatory authority has restricted instruction via electronic means of communication to the S1 area. This means that instruction can no longer be given via electronic means of communication from security level 2 onwards. If Zoom or other meeting portals or videos with questions were to be used for instruction, this would be subject to a fine even if the authority had approved it. This is because Section 17 Paragraph 4 Sentence 2 GenTSV, like Section 33 No. 8 GenTSV, is not dispositive, i.e. the authority can neither allow exceptions to the statutory provision nor deviate from it. In this respect, the will of the legislature is clearly currently in conflict with laboratory practice and the views of the genetic engineering authorities.