PL certificate, but not ordered as PL! What now?
Dr. Petra Kauch
Another unresolved problem with the 5-year continuing education requirement according to Section 28 Para. 3 S. 1 GenTSV (2019)
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They also exist: the numerous participants in project management courses who, between 1990 and today, obtained a project management certificate in accordance with Section 15 (4) of the GenTSV and yet were not appointed as project managers (PL) or biological safety officers (BBS). These will face a problem by 2016 at the latest: The law does not specify what will happen in 2026 to unassigned project managers who have not completed their first five-year training. On the one hand, this could mean that such project management certificate holders cannot be updated in a one-day course in accordance with Section 28 (3) Sentence 1 of the GenTSV (2019), but must again participate in a two-day PL course in accordance with Section 28 (5) of the GenTSV (2019) = basic course. On the other hand, however, it is recognized that a subsequent extension is also possible for the five-year extension period for a driver's license. For example, someone who doesn't use their truck driving license regularly might forget to renew it in time. This isn't necessarily a problem with driving licenses, as retroactive renewal is generally possible. However, it is questionable whether the Genetic Engineering Authority will actually recognize the one-day course pursuant to Section 28 (3) Sentence 1 of the Genetic Engineering Act (GenTG) (2019) under genetic engineering law. For this reason, it also seems advisable for project manager license holders who are currently neither PL nor BBS to update themselves in a timely manner in accordance with Section 28 (3) Sentence 1 of the GenTSV (2019) if they do not want to lose their previously acquired project manager license as part of their expertise. This deadline is viewed differently in the federal states. In some cases, the February 28, 2021, deadline has already expired; in some states, the initial deadline is granted until February 28, 2026. Even in federal states where the shorter deadline applies, project manager certificate holders will be accepted during 2021 if they have registered for at least one course. Therefore, project manager certificate holders who are not employed as PLs or BBSs still have the opportunity to update their registration during the course of the year in accordance with Section 28 Paragraph 3 Sentence 1 of the GenTSV (2019). They will then be automatically re-registered by the provider of such a course to the relevant district government/regional council/ministry and will have an updated file number to provide to their authority should they be appointed as PLs or BBSs in the future.