ENVIRONMENTAL RISK MANAGEMENT AUTHORITY DECISION Amended under s67A on 01 February 2005 and 22 August 2007 Date Signed: 23 June 2004 Application code: GMD03105 Application category: Develop in Containment any New Organism under the Hazardous Substances and New Organisms (HSNO) Act 1996 Applicant: AgResearch Limited Private Bag 3123 HAMILTON 2001 Applicant contact: Allan Nixon Purpose: To ascertain in containment, the functions of genes associated with growth of hair and skeletal and cardiac muscle, by altering the expression of those genes in animal cells and tissues using replication-deficient viral vectors. Date application received 26 April 2004 Consideration date: 8 June 2004 Considered by: Committee of the Authority 1 Summary of Decision The application to develop in containment the organisms as listed in Table 1: has been approved with controls, having been considered in accordance with the relevant provisions of the Hazardous Substances and New Organisms Act 1996 (the HSNO Act) and the HSNO (Methodology) Order 1998 (the Methodology). Table 1: Approved organisms Host Organism modified by the vector and Donor DNA on the right Vector and Donor DNA Homo sapiens cell lines (293 derivatives, 911, PER.C6) (GMD03105) Modified by recombinant mammalian expression plasmids and retroviral (including lentiviral) or adenoviral plasmids containing genetic material1 from sheep, cattle, human2 or mouse involved in cell survival, cell proliferation, cell differentiation/maturation and development of muscle, skin and hair including: Mus musculus cell lines (NIH 3T3 derivatives) (GMD03105) 1. growth factors 2. developmental regulators 3. hormone receptors 4. cell adhesion molecules 5. cell survival and cell cycle associated genes 6. transcription factors 7. other genes involved in regulating the cell proliferation, differentiation, survival or development of muscle, skin and hair. Colourimetric and fluorescent reporter genes Selectable markers The cDNA sequences described above may have regulatory or localisation sequences fused to them such as: Protein tags including histidine (His), FLAG, V5 epitope and Lumio hexameric protein tag. Promoters including CMV, UbC, MMLV 5’LTR, keratin 14, myostatin, myosin light chain, muscle creatine kinase, RSV, U6 Regulatory elements/systems including polyadenylation signals, internal ribosomal entry sites, recombination sites, ecdysone regulated system, tetracycline regulated system. Other commercially available promoter or regulatory elements. 1 sense cDNAs, sense constructs containing nucleotide substitution or deletions (to determine functional domains), antisense and RNA interference sequences 2 Non-Māori only Environmental Risk Management Authority Decision: Application GMD03105 Page 2 of 17 Host Organism modified by the vector and Donor DNA on the right Mus musculus cell lines (primary and immortalised) (GMD03105) Vector and Donor DNA Modified by retroviral (including lentiviral) or adenoviral vectors containing genetic material3 from sheep, cattle, human or mouse involved in cell survival, cell proliferation, cell differentiation/maturation and development of muscle, skin and hair including: 1. growth factors 2. developmental regulators Homo sapiens cell lines (primary and immortalised) (GMD03105) 3. hormone receptors 4. cell adhesion molecules 5. cell survival and cell cycle associated genes Ovis aries cell lines (primary and immortalised) (GMD03105) 6. transcription factors 7. other genes involved in regulating the cell proliferation, differentiation, survival or development of muscle, skin and hair. Rattus norvegicus cell lines (primary and immortalised) (GMD03105) Colourimetric and fluorescent reporter genes Bos taurus cell lines (primary and immortalised) (GMD03105) Protein tags including histidine (His), FLAG, V5 epitope and Lumio hexameric protein tag. Promoters including CMV, UbC, MMLV 5’LTR, keratin 14, myostatin, myosin light chain, muscle creatine kinase, RSV, U6 Regulatory elements/systems including polyadenylation signals, internal ribosomal entry sites, recombination sites, ecdysone regulated system, tetracycline regulated system. Other commercially available promoter or regulatory elements. Cricetulus griseus cell lines (primary and immortalised) (GMD03105) Selectable markers The cDNA sequences described above may have regulatory or localisation sequences fused to them such as: Coturnix japonica cell lines (primary and immortalised) (GMD03105) Mus musculus (GMD03105) Rattus norvegicus (GMD03105) 3 sense cDNAs, sense constructs containing nucleotide substitution or deletions (to determine functional domains), antisense and RNA interference sequences. Environmental Risk Management Authority Decision: Application GMD03105 Page 3 of 17 This application was required to be considered by the Authority as it included developments that were considered “not low-risk” genetic modifications (clause 1(e) of the Schedule of the HSNO (Low-Risk Genetic Modification) Regulations 2003) involving “viral vectors whose host range includes human cells and that contain one or more inserted nucleic acid sequence(s) coding for a product that can lead to uncontrolled mammalian cellular proliferation or be toxic to mammalian cells, or both”. 2 Legislative Criteria for Application The application was lodged pursuant to section 40(1)(b) of the HSNO Act. The decision was determined in accordance with section 45, and matters relevant to the purpose of the HSNO Act, as specified under Part II of that Act. Unless otherwise stated, references to section numbers in this decision refer to sections of the HSNO Act. Consideration of the application followed the relevant provisions of the Methodology, with particular regard to clauses 12 (dealing with assessment of risks) and 13 (dealing with assessment of costs and benefits). Unless otherwise stated, references to clause numbers in this decision refer to clauses of the Methodology. Application Process Application GMD03105 was formally received and verified on 26th April 2004 as having adequate information for processing. In accordance with section 58(c) of the HSNO Act and clause 5 of the Methodology the Department of Conservation (DoC) and Ministry of Agriculture and Forestry (MAF) were invited to comment on this application. There were no comments from MAF. The response of DoC was included in Appendix 2 of the Evaluation and Review (E&R) report. Information Available for Consideration The documents available for the consideration of the application by ERMA New Zealand were: Application GMD03105: develop within a containment structure any genetically modified organism (other than by rapid assessment). The application also included appendices. E&R Report prepared by the Agency to assist and support the Committee's decision-making. Comments from DoC on the application. The Committee considered the application and supporting information. The Committee considered that the application was extremely comprehensive. Recognised techniques were used in identifying, assessing, and evaluating the relevant information, as required under clause 24 of the Methodology. Techniques for Environmental Risk Management Authority Decision: Application GMD03105 Page 4 of 17 identifying and preparing information on risks, costs and benefits were based on internal procedures as specified in the ERMA New Zealand Technical Guide publications. Decision Making Committee The application was considered by the Genetically Modified Organism Standing Committee of the Authority, appointed in accordance with section 19(2)(b) of the HSNO Act and clause 43 of the First Schedule. That Committee comprised the following members: Associate Professor Marie Dziadek (Chair) and Dr Max Suckling. 3 Sequence of the Consideration In accordance with clause 24 of the Methodology, the approach adopted by the Committee was to look sequentially at identification, assessment and evaluation of risks, costs and benefits. Interposed with this was the consideration of the adequacy of the proposed containment regime, and the ability of the organism to escape and to form a self-sustaining population. Management techniques were considered in relation to the identified risks (clause 24) and those risks identified as significant were assessed (clause 12). Costs and benefits were assessed in accordance with clause 13 of the Methodology. Finally, taking account of the risk characteristics established in accordance with clause 33 of the Methodology, the combined impact of risks, costs and benefits was evaluated in accordance with clause 34. Purpose of the Application AgResearch Limited sought approval “to ascertain in containment, the functions of genes associated with growth of hair and skeletal and cardiac muscle, by altering the expression of those genes in animal cells and tissues using replication-deficient viral vectors.” In accordance with section 45(1)(a)(i) of the HSNO Act, the Committee determined that the purpose was appropriate under 39(1)(a) of the HSNO Act: The development of any genetically modified organism. The Sequence of Steps in the Consideration In accordance with clause 24 of the Methodology, the approach to the consideration adopted by the Committee was to first examine the scope of the application, and the range of organisms applied for, then to look sequentially at the identification, assessment and evaluation of risks, costs and benefits. Qualitative scales used by the Committee to measure likelihood and magnitude of risks, costs and benefits were provided in Appendix 3 of the E&R report. In assessing risks and costs, issues affecting the adequacy of the containment regime and the potential for population establishment and population eradication were considered (as required by sections 37 and 44 of the HSNO Act and clause 10(e) of the Methodology). The containment regime was considered in the context of a risk Environmental Risk Management Authority Decision: Application GMD03105 Page 5 of 17 management regime for controlling the identified risks and costs (clauses 12(d) and 24). In doing so, the Committee set controls to satisfactorily provide for the matters in the Third Schedule (Part I) of the HSNO Act. It was then considered whether or not there were any residual risks that required further consideration. Benefits associated with this application were considered in accordance with clauses 9, 10, 13 and 14 of the Methodology and section 6(e) of the HSNO Act. Scope of Application and Organism Description The scope of the organisms subject to the approval is limited to that described above in Table 1: Approved organisms. This approval covers several stages of a development, resulting in the development of genetically modified cell lines and rodents. These stages are: Generation of recombinant adenoviral and retroviral (including lentiviral) vectors in Homo sapiens and Mus musculus cell lines (PC2, Schedule 1(e) under HSNO (Low-Risk Genetic Modification) Regulations 2003). Genetic modification of mammalian and avian cell lines with adenoviral and lentiviral vectors (PC2, Schedule 1(e) under HSNO (Low-Risk Genetic Modification) Regulations 2003). Genetic modification of rodents with adenoviral and lentiviral vectors (PC2, Schedule 1(e) under HSNO (Low-Risk Genetic Modification) Regulations 2003). The Committee noted the wide scope of donor DNA and acknowledged that there would be some unknown genes used. The Committee considered that the risk was minimised by using a step-wise approach of in vitro and then in vivo techniques. The Committee noted the use of “any other commercially available promoter or regulatory elements/systems yet to be developed”. The Committee considered that commercially developed elements or systems would not notably change the overall risk profile of the application. The Committee noted that there was no intent to generate any germ-line genetic changes in the rodents. The Committee noted that the applicant was planning on using primary human cell lines. However, these would be imported and not created in New Zealand. 4 Identification of potential adverse effects The Committee identified risks and costs related to the application in accordance with clauses 9 and 10 of the Methodology, which incorporate sections 5, 6, 8 and 43 of the HSNO Act. The Committee considered section 4 (Identification of potential risks, costs and benefits) of the E&R report when carrying out the identification of potential adverse and beneficial effects (risks, costs and benefits). The Committee did not identify any Environmental Risk Management Authority Decision: Application GMD03105 Page 6 of 17 other potential adverse effects other than those outlined in section 4 of the E&R report. Adverse environmental effects The Committee records that risks to the environment were considered, in accordance with clauses 9(a)-9(c) and 10 of the Methodology. The Committee accepts the conclusions reached in the E&R Report that the development and use of the organisms in containment is very unlikely to pose significant risks to the environment. The Committee considered that risks to the environment discussed within the E&R report to be negligible and no further consideration of these aspects was warranted. Māori and their culture and traditions The Committee considered the potential adverse Māori cultural effects and noted sections 4.1 and 6.40 – 6.46 of the E&R Report. The Committee considered the potential cultural effects in accordance with clauses 9(b) and 9(c)(iv) of the Methodology and sections 5(b), 6(d) and 8 of the HSNO Act. The Committee noted that the applicant had undertaken consultation with Ngāti Wairere and Te Kotuku Whenua consultants and as a result of the consultation, no unresolved issues remained. The Committee accepts the conclusions reached in the E&R Report that potential risks to the whakapapa, mauri and tapu of native or valued fauna caused by the regeneration, escape and transfer of recombinant viral vectors would be minimal in magnitude and highly improbable in likelihood. The Committee considered the risks posed to Māori to be negligible. Therefore, no further consideration of these effects was warranted. Adverse effects on human health and safety The Committee identified that adverse health effects on human health and safety due to occupational exposure was a potentially significant adverse effect in accordance with clauses 9 and 10 of the Methodology and is further discussed in section 6 of this decision document. Adverse effects to society and the community The Committee considered that no adverse effects to society and community were identified that were not more comprehensively covered in other sections of the consideration. Therefore, no further consideration of these aspects was warranted. Adverse effects on the economy The Committee records that adverse effects on the economy were considered in accordance with clauses 9(a)-9(c) and 10 of the Methodology. The Committee accepts the conclusions reached in the E&R Report, that risk of these adverse effects is negligible; therefore, no further consideration of these aspects was warranted. Environmental Risk Management Authority Decision: Application GMD03105 Page 7 of 17 5 Adequacy of the Proposed Containment Regime In assessing risks and costs, the Committee considered issues affecting the adequacy of the containment regime (in accordance with section 45(1)(a) of the HSNO Act); the potential for population establishment and population eradication (sections 37 and 44 of the HSNO Act and clauses 10(e) and 10(f) of the Methodology); and other matters in order to give effect to the purpose of the HSNO Act (section 45(2)(b)). Risk management techniques were used in relation to the identified risks and costs (clauses 12(d) and 24 of the Methodology). As such, the assessment of risks and costs (refer to section 7 of this decision) was taken into account in setting the containment requirements that are discussed in this section. Ability to adequately contain the organism In considering the ability of the organism to escape from containment, the Committee considered the: i. biological characteristics of the organism ii. potential pathways for escape of the organism from the containment facility iii. proposed containment regime iv. ability of the organism to establish a self-sustaining population. The controls imposed by this approval (as specified in Appendix 1) address the matters detailed in the Third Schedule Part I of the HSNO Act: Matters to be addressed by containment controls for importing, developing or field testing of genetically modified organisms under the Act. Additional controls to give effect to the purpose of the HSNO Act have also been included. These controls incorporate the requirement for managing risks and costs (under clauses 12(d) and 24 of the Methodology) posed by the genetically modified viral vectors, cell lines and rodents subject to this approval. The controls have been imposed to ensure that exposure of laboratory workers and other persons, and the outside environment, to risks and costs posed by the organisms is negligible. The Committee examined the information supplied by the applicant explaining how operation of the facility worked while work with viral vectors was being undertaken. Procedures to be followed included, vectors would be separated temporally and the same work would be conducted in series for each viral vector type with decontamination procedures between. The Committee agreed that the applicant’s procedures in place for the operation of the PC2 laboratory were satisfactory and only temporal separation was necessary as the applicant was not intending to work with more than one viral vector at a time. The Committee noted that the applicant was planning on manufacturing the recombinant viruses, purifying and then storing them in a freezer. Therefore, the Committee considered it highly improbable that recombination could occur between different viral vectors and did not require the applicant to monitor for undesired recombination events Environmental Risk Management Authority Decision: Application GMD03105 Page 8 of 17 Ability of Organism to Establish a Self-sustaining Population and the Ease of Eradication In accordance with sections 44 and 37 of the HSNO Act the Committee considered the ability of the organism to establish undesirable self-sustaining populations, should it escape from containment and the ease with which such populations could be eradicated. The Committee considers that with the containment controls it has imposed (refer to Appendix 1 of this decision); it is highly improbable for the cell lines or rodents modified with viral vectors to escape or to be removed inadvertently from the containment facility and to establish self-sustaining populations. 6 Assessment of the Risks, Costs and Benefits The potential risks and costs assessed here are those identified as significant, having regard for those matters set out in clauses 9 and 10 of the Methodology. Risks were considered in terms of the requirements of clause 12 of the Methodology, including the assessment of consequences and probabilities, the impact of uncertainty and the impact of risk management. Costs were considered in terms of clause 13 of the Methodology. The evidence available was scientific in nature and was considered in terms of clause 25(1) of the Methodology. This evidence comprised principally that provided by the applicant and additional evidence set out in the E&R Report. In section 4 above, the Committee identified a potentially significant adverse effect on human health and safety from viral vectors infecting laboratory workers via accidental injection or inhalation of aerosols. What follows is the assessment of those adverse effects. Potential adverse effects to human health and safety The Committee considered the adverse health and safety effects due to occupational exposure in accordance with clauses 12, 13 and 14 of the Methodology. The degree of uncertainty attached to the evidence is taken into account, as required under clauses 25(1), 29, 30, 32 and 33 of the Methodology. The Committee considered the E&R report (sections 6.19 to 6.35) to contain an excellent analysis of the potential adverse effects on human health and safety resulting from occupational exposure to recombinant viral vectors. The Committee considers that in the event of an inadvertent injection of viral particles, the low viral titre and the replication defective nature of the virus used in this study, will limit the effects to a minimum and the infection will be localised to the injection site. Further, the Committee noted that a person experienced with the use of viruses or recombinant viral vectors shall maintain oversight of the experiments, and shall organise training for staff in best practice procedures for risk reduction (additional control 8.1, Appendix 1 of this document). The Committee agrees with the E&R report (section 5.13) that the oversight of the experiments proposed in this application by a scientist experienced with the use of Environmental Risk Management Authority Decision: Application GMD03105 Page 9 of 17 recombinant viral vectors will reduce the occupational health risk to staff (additional control 8.1, Appendix 1 of this document). The Committee agreed with the E&R report (section 5.21) that the use of a class II biological safety cabinet as mentioned in additional control 8.2 (see Appendix 1 of this document) should minimise the risk to laboratory workers. The Committee agreed with the E&R report (section 5.42-5.44) that in order to minimise the risk of accidental colonisation of workers with infected cell lines, laboratory workers should not infect cultures of their own cells, nor, as a general rule, those of their immediate family or other members of the laboratory (additional control 8.3 , Appendix 1 of this document).The Committee agreed with the E&R report (section 5.50) that it will be highly improbable laboratory personnel will be infected during this work if there is strict adherence to the containment standards and additional controls. Therefore, taking in account the controls (particularly the additional controls) they considered that the risk of potential adverse effect to human health and safety as a result of occupational exposure to recombinant viral vectors to be negligible. Assessment of Costs A “cost” is defined in clause 2 of the Methodology as “the value of a particular adverse effect expressed in monetary or non-monetary terms”. The Committee did not identify any costs that would be incurred by the approval of the application other than those to the applicant. Assessment of benefits (beneficial effects) The Committee agreed with the E&R report and identified the following benefits associated with the application, in accordance with the Methodology clauses 9, 10, 13 and 14, and section 6(e) of the HSNO Act: The Committee considered that the direct benefits of this application are those of gains in scientific knowledge and scientific reputation and standing for the researchers. The Committee considered that these benefits are very likely to occur based on the applicant’s track record in securing grants and funding and their publications in top-tier peer-reviewed scientific journals. Also, the Committee considered that these benefits will be shared between the applicant, who may secure international collaborations or attract grant funding as a result, and the greater scientific community when the results of the research are published and become available in the public domain. However, the Committee note that these benefits are research-based and the outcomes cannot be defined with a great deal of certainty. The Committee considers that potentially the research could have significant nonmonetary benefits for human health in the long-term if the applicant was able to develop novel therapeutic strategies for treatment or, to enhance recovery from muscle or skin disorders. The diseases the researchers are attempting to develop therapy strategies for are serious diseases and any scientific breakthrough that contributed to some type of therapy to alleviate these conditions would be of major benefit to the community. However, the Committee notes that there is a large degree Environmental Risk Management Authority Decision: Application GMD03105 Page 10 of 17 of uncertainty surrounding expected long-term non-monetary benefits, as it depends on how successful the research is and on a number of other factors. The Committee noted that potentially the research could have significant nonmonetary benefits for animal welfare in the long-term if they were able to develop products that maintain healthy muscle mass and improve distribution of the fleece in farm animals (section 6.50 of the E&R report). The Committee noted there is a large degree of uncertainty surrounding these potential long-term benefits and that there was insufficient information at this stage in the research to determine the likelihood or magnitude of such long-term benefits. 7 Establishment of the Approach to Risk in the Light of Risk Characteristics Clause 33 of the Methodology requires the Authority to have regard to the extent to which a specified set of risk characteristics exist when considering applications. This provision provides a route for determining how cautious or risk averse the Authority should be in weighing up risks and costs against benefits. In the present application, clause 33 is influenced by the application being “in containment” and the conclusion drawn is that the containment provisions and other controls will reduce most biological and physical risks to a low level. In relation to the biological and physical risks considered, the containment measures limit the extent to which exposure to the risks is involuntary. Given the Committee's finding that the risk of this occurring is highly improbable, the extent to which these risk characteristics are present does not warrant caution additional to that required by section 7 of the Act. 8 Other matters The Committee considered that no other matters were relevant in setting controls outside the Third Schedule, in order to give effect to the purpose of the HSNO Act (in accordance with section 45(2)(b)). 9 International and related matters The Committee considered there were no international obligations relevant to this approval in accordance with clause 9(c)(vi) of the Methodology and section 6(f) of the HSNO Act. 10 Overall Evaluation of Risk, Costs and Benefits In reaching its decision on this application, the Committee records that the following criteria in the HSNO Act and the Methodology have been particularly relied on (in accordance with clauses 21 and 36(2)(b) of the Methodology): The application has been considered in the context of the purpose and principles of the HSNO Act (sections 4-8 inclusive). Environmental Risk Management Authority Decision: Application GMD03105 Page 11 of 17 Pursuant to section 45(1)(a)(i) of the HSNO Act, the Committee is satisfied that the purpose of the application falls under section 39(1)(a): the development of any genetically modified organism. In accordance with section 45 of the HSNO Act, and clauses 9, 10 and 12 of the Methodology, the Committee concluded that each of the risks and costs was negligible taking into account the containment regime and the controls. Thus, the Committee considered the application under clause 26 of the Methodology. A number of potentially significant risks are considered to be negligible, after taking account of the organism description and the impact of containment and other controls set out in Appendix 1. As assessed earlier in this document the benefits are largely scientific. While these benefits are very likely to exist, their magnitude may range from minimal to moderate depending on the success of the research and the scientific value of the research results. The Committee noted that potentially the benefits could include positive outcomes for both human health and animal welfare product development. The Committee noted that these benefits were potentially significant depending on the outcome of the research. However, the Committee considered that it that there was insufficient information at this stage in the research to determine the likelihood or magnitude of such long-term benefits. The Committee then considered whether, given the organism description and the containment and controls proposed, the benefits outweigh the significant risks and costs. The Committee’s view is that the benefits do outweigh the costs and risks. The Committee is satisfied that the cell lines and rodents transduced with recombinant viral vectors can be adequately contained (sections 45(1)(a)(iii) and 44(b) of the HSNO Act), by the controls required in this decision (refer to Appendix 1). In accordance with clause 36(2)(b) of the Methodology, the Committee records that in reaching this conclusion, it has applied the balancing tests in section 45 of the HSNO Act. 11 Decision 1. Pursuant to section 45(1)(a)(i) of the Hazardous Substances and New Organisms Act 1996, the Committee is satisfied that this application is for one of the purposes specified in section 39(1) of the Act, being section 39(1)(a): the development of any genetically modified organism. Having considered all the possible effects in accordance with sections 45(1)(a)(ii) and 44 and pursuant to clause 26 of the Methodology, and based on consideration and analysis of the information provided and taking into account the application of risk management controls specified in this decision, the view of the Committee is that the risks (or costs) of adverse effects associated with the development in containment of the organisms listed in table 1 are outweighed by the benefits. 2. The Committee is satisfied that the proposed containment regime, as set out in Appendix 1, will adequately contain the organism as required by section 45(1)(a)(iii) of the Hazardous Substances and New Organisms Act 1996. Environmental Risk Management Authority Decision: Application GMD03105 Page 12 of 17 3. In accordance with clause 36(2)(b) of the Methodology the Committee records that, in reaching this conclusion, it has applied the balancing tests in section 45 of the Hazardous Substances and New Organisms Act 1996 and clause 26 of the Methodology and has relied in particular on the criteria set out in the following sections of the Act: section 44 additional matters to be considered; section 45 determination of application; section 37 additional matters to be considered; The Third Schedule-Part I matters to be addressed by containment controls developing of genetically modified organisms. 4. The Committee has also applied the following criteria in the Methodology: clause 9 - equivalent of sections 5, 6 and 8; clause 10 - equivalent of sections 36 and 37; clause 12 – evaluation of assessment of risks; clause 13 – evaluation of assessment of costs and benefits; clause 21 – the decision accords with the requirements of the Hazardous Substances and New Organisms Act 1996 and Regulations; clause 22 – the evaluation of risks, costs and benefits – relevant considerations; clause 24 – the use of recognised risk identification, assessment, evaluation and management techniques; clause 25 – the evaluation of risks; clause 26 - the risks and costs are negligible and outweighed by the benefits; clause 33 – the risk characteristics; and clause 34 – the aggregation and comparison of risks, costs and benefits. 5. The application for development in containment of organisms described in table 1 is thus approved, with controls, as set out in Appendix 1. Associate Professor Marie Dziadek Chair of Decision-making Committee Date: 23 June 2004 Organism approval codes: GMD003193 - GMD003202 Environmental Risk Management Authority Decision: Application GMD03105 Page 13 of 17 Amendment: February 2005 Amended to correct a technical error in the controls by adding the ‘MAF Biosecurity Authority/ERMA New Zealand Standard 154.03.03: Containment Facilities for Vertebrate Laboratory Animals’ and by altering subsequent references to containment standards in the controls so that both standards that are relevant to this approval apply. Associate Professor Marie Dziadek Chair of Decision-making Committee Date: 1 February 2005 Amendment: November 2006 Changes to controls: Addition of footnotes to the containment facility references and the Australian/New Zealand containment facility references to “future proof” the decision Standardise the wording of the breach of containment control Removal of the control regarding inspection of facilities by the Authority, its agent or enforcement officers ____________________________ Date: 22 August 2007 Dr Kieran Elborough Chair, GMO Standing Committee Environmental Risk Management Authority Decision: Application GMD03105 Page 14 of 17 Appendix 1: Controls In order to satisfactorily address the matters detailed in the Third Schedule Part I: Matters to be Addressed by Containment Controls for Development and Field Testing of Genetically Modified Organisms4of the Act, and other matters in order to give effect to the purpose of the Act (section 45(2)), the approved organism is subject to the following controls: 1 To limit the likelihood of any accidental release of any organism or any viable genetic material5 : 1.1 The person responsible for a particular research area and/or the person responsible for the operation of the containment facilities (‘the facility’) shall inform all personnel involved in the handling of the organisms of the Authority’s controls. 1.2 For the work with mammalian cell lines and production of viral vectors the containment facilities shall be approved by Ministry of Agriculture and Forestry (MAF), in accordance with the MAF Biosecurity Authority/ERMA New Zealand Standard 154.03.026: Containment Facilities for Microorganisms Physical containment level 2 (PC2) and the controls set out by Authority. 1.3 For the work with the transgenic rodents the containment facilities shall be approved by Ministry of Agriculture and Forestry (MAF), in accordance with the MAF Biosecurity Authority/ERMA New Zealand Standard 154.03.036: Containment Facilities for Vertebrate Laboratory Animals Physical containment level 2 (PC2) and the controls set out by Authority. 2 To exclude unauthorised people from the facility: 2.1 The identification of entrances, numbers of and access to entrances, and security requirements for the entrances and the facility shall be in compliance with the requirements of the standards listed in control 1.2 and 1.3 of this document. 3 To exclude other organisms from the facility and to control undesirable and unwanted organisms within the facility: 4 Bold headings refer to matters to be addressed by containment controls for new organisms excluding genetically modified organisms, specified in the Third Schedule (Part II) of the HSNO Act 1996. 5 Viable genetic material is biological material that can be resuscitated to grow into tissues or organisms. It can be defined to mean biological material capable of growth even though resuscitation procedures may be required, e.g. when organisms or parts thereof are sub lethally damaged by being frozen, dried, heated, or affected by chemical. 6 Any reference to this standard in these controls refers to any subsequent version approved or endorsed by ERMA New Zealand Environmental Risk Management Authority Decision: Application GMD03105 Page 15 of 17 3.1 The exclusion of other organisms from the facility and the control of undesirable and unwanted organisms within the facility shall be in compliance with the standards listed in control 1.2 and 1.3 of this document. 4 To prevent unintended release of the organism by experimenters working with the organism: 4.1 The prevention of unintended release of the organisms by experimenters working with the organisms shall be in compliance with the standards listed in control 1.2 and 1.3 of this document. 5 To control the effects of any accidental release or escape of an organism: 5.1 Control of the effects of any accidental release or escape of the organisms shall be in compliance with the standards listed in control 1.2 and 1.3 of this document. 5.2 In the event of any breach7 of containment the contingency plan for the attempted retrieval or destruction of any viable material of the organisms that have escaped shall be implemented immediately. The contingency plan shall be included in the containment manual in accordance with standards listed in control 1.2 and 1.3 of this document. 5.3 If a breach of containment occurs, the facility operator must ensure that the MAF Inspector responsible for supervision of the facility has received notification of the breach within 24 hours. 6 Inspection and monitoring requirements for containment facilities: 6.1 The inspection and monitoring requirements for the containment facilities shall be in compliance with the standards listed in control 1.2 and 1.3 of this document. 6.2 The Containment Manuals shall be updated, as necessary, to address the implementation of the controls imposed by this approval, in accordance with the standards listed in control 1.2 and 1.3 of this document. 7 Qualifications required of the persons responsible for implementing those controls: 7.1 The training of personnel working in the facility shall be in compliance with the standards listed in control 1.2 and 1.3 of this document. For the purposes of these controls a ‘breach of containment’ means any interference with the containment facility or any non-compliance with Authority’s controls whether an approved organism escapes from containment or not. 7 Environmental Risk Management Authority Decision: Application GMD03105 Page 16 of 17 8 Additional Controls 8.1 A scientist experienced with the use of recombinant viral vectors shall at all times maintain oversight of the experiments, and shall provide training to staff in best practice procedures for risk reduction. 8.2 A biological safety cabinet of class II shall be used for all experiments requiring PC2 containment where the handling of viral vectors may result in the production of aerosols. 8.3 Under no circumstances should investigators be infecting cultures of their own cells, or of their immediate relatives, or those of other staff of the laboratory. Environmental Risk Management Authority Decision: Application GMD03105 Page 17 of 17