Policy and Procedures Florida A&M University Institutional Biosafety Committee Table of Contents I. Introduction II. Principal Investigators III. Preparing the Protocol A. Is IBC Review Required? B. Protocol Submission 1. Protocol Submission Form IV. Risk Group Determination A. Risk Group 1 B. Risk Group 2 V. Biosafety Levels A. Biosafety Levels for Infectious Agents B. Biosafety Levels for Vertebrate Animal VI. Select Agents VII. IBC Procedures for the Review of Protocols and Amendments A. Committee Review of New Protocols Types of Review B. Review of Amendments C. Protocol/Amendments Status VIII. Protocol Renewals IX. Termination of a Protocol X. Transferring a Protocol to Another Investigator XI. Other Committees Related to the IBC A. Institutional Animal Care and Use Committee (IACUC) B. Institutional Review Board (IRB) XII. Relationship Between the Greenhouse and the IBC XIII. Responsibilities of the Principle Investigator XIV. Responsibilities of the Participants XV. Adverse Events POLICY AND PROCEDURES FOR THE INSTITUTIONAL BIOSAFETY COMMITTEE (IBC) I. Introduction The IBC is charged with the responsibility for review, approval and surveillance of all research protocols at Florida A&M University involving the use of biohazards including recombinant DNA, agents infectious to humans, animals or plants, and other genetically altered organisms and agents. All research at the University involving biohazards, regardless of its source of financial support, must be approved by the IBC and must conform to IBC policies and principles. The Vice President for Research has the responsibility for enforcing IBC decisions and recommendations based on federal and institutional policies and procedures. The IBC membership is comprised of: faculty members selected that they collectively have experience and expertise in recombinant DNA technology, biological safety, and physical containment; and at least one community member who represents the interest of the surrounding community. Membership reflects basic federal requirements for expertise and advocacy; additional members are added as necessary or appropriate. The Vice President for Research appoints all IBC members, including the Chair. The term of membership is three years. All terms are renewable upon mutual agreement between the Vice President, the IBC Chair and the IBC member. The IBC has a Vice-Chair who is called upon to serve in the Chair's absence. A current membership roster is available from the Office of Animal Care and Research and their website (http://research.famu.edu). The Office of Animal Care and Research Compliance is the administrative office responsible for coordinating IBC activity. The Office is located in Room 130 Dyson Building. The Director for Animal Care and Research Compliance for Laboratory is Tanise L. Jackson, DVM, who is responsible for the committee and can be reached at (850) 599-3214. If there are questions or concerns related to IBC activities, the IBC staff can be reached at (850) 412-5246. II. Principal Investigators The Principal Investigator (PI) is responsible for the overall conduct of the study, including modifications to the original submission. In addition, the PI receives all correspondence from the IBC including the continuing review material. Individuals who are eligible to serve as PIs on proposals for external funding may also serve as principal investigators on protocols. In general, these individuals have faculty appointments at Florida A&M University. The faculty member’s name must appear as PI on the Protocol Submission Form, and his/her signature must appear on the signature page. The faculty sponsor will be designated as PI for the protocol; all others are listed as participants. Any investigator other than the PI must be designated as a participant on the Protocol Submission Form. The IBC must be notified in writing when participants are added to or removed from the protocol. Only the named and approved principal investigator and participant(s) may carry out any procedure outlined in the IBC protocol. Page 1 of 14 III. Preparing the Protocol A. Is IBC Review Required? Occasionally, it may not be apparent that IBC review is required for a particular research project. This will typically happen when a protocol is being submitted to the Institutional Animal Care and Use Committee (IACUC) or the Institutional Review Board (IRB). During their review, these Committees may question whether the protocol should also be submitted to the IBC. In this event, the PI is requested to submit an abstract or summary of the proposed work to the IBC staff, which will be forwarded to the IBC Chair or his/her designee for review. The Chair or his/her designee will determine whether IBC review is required. The PI will be notified of the Chair’s determination and the IACUC or IRB will be notified if applicable. If IBC review is not required, documentation will be kept in file folder “Research Not Requiring IBC” in the IBC office. If IBC review is required, the PI will be contacted and requested to submit the required submission forms. Any documentation related to this will be included in the protocol file. B. Protocol Submission All research involving biohazards conducted at Florida A&M University must be submitted to the IBC for approval prior to initiation. IBC forms, policies, and procedures are periodically revised to ensure that the information meets current regulatory requirements and that the IBC has information needed for a complete review of the research. Review of a protocol could be delayed if further information is required. All protocol applications must use the current approved submission form. The most up-to-date version of the IBC forms are available on the OACRC website at http://research.famu.edu. or by hard copy in the IBC office in Room 130 Dyson Building. The principal investigator must submit the original and any other relevant materials to the IBC. 1. Protocol Submission Form The Submission Form is designed to highlight areas of IBC concern. Therefore, the form should provide an accurate and complete summary of the research project. The principal investigator must sign the original. Most current IBC protocols at The University of Chicago fall under Risk Group 1 or 2. The following section describes the difference in submission requirements for Risk Group 1 and 2. Refer to the NIH Guidelines for Research Involving Recombinant DNA Molecules, January 2001 or http://www4.od.nih.gov/oba/rac/guidelines/guidelines.html to determine risk group. IV. Risk Group Determination A. Risk Group 1 Risk Group 1 agents are not associated with disease in healthy adult humans; typically recombinant DNA (rDNA) work with E. coli is RG1. Protocols that fall under Risk Group 1 must complete sections I-VI of the protocol submission form. All laboratories must have a biosafety manual. Laboratories, other than those using a Risk Group 2 agent, may adopt the CDC/NIH Biosafety in Microbiological and Biomedical Laboratories (4th Edition) as their principle biosafety laboratory manual, http://www.cdc.gov/od/ohs/biosfty/bmbl4/bmbl4toc.htm . The applicable sections of the manual for the risk group and biosafety level of the protocol must be available in the laboratory and to the personnel listed on the protocol. Generally, Risk Group 1 research also falls under Biosafety Level 1. Page 2 of 14 B. Risk Group 2 Risk Group 2 agents are associated with human disease which are rarely serious and for which preventive or therapeutic interventions are often available. For protocols who fall under Risk Group 2, the entire submission form including section VII must be completed along with developing a supplemental biosafety manual. The manual must identify the hazards that will or may be encountered and must specify practices and procedures, designed to minimize or eliminate risks. The manual must be submitted to the IBC with the protocol for review. Personnel listed on the protocol must be advised of special hazards and are required to read and to follow the required practices and procedures described in the manual. Typical topics for the manual include but are not limited to: overview of agent, general safety procedures for laboratory, disposal procedures, biosafety level requirements, procedures for handling animals in the laboratory, procedures for handling the agent, decontamination procedures, spill/accident procedures, personal protective equipment required, and procedures to take in the event of an exposure to the agent, (include concentrations, length of time bleach needs to sit, efficacy). Generally, Risk Group 2 research falls under Biosafety Level 2. V. Biosafety Levels The CDC and NIH have established four levels of protection for research involving infectious microorganisms and laboratory animals. The levels are designated in ascending order, by degree of protection provided to personnel, the environment, and the community. Biosafety levels were created to represent the conditions under which the agent ordinarily can be safely handled. The four biosafety levels are described below. Occasionally, protocols may be approved with biosafety level 2 with biosafety level 3 practices. Generally, biological safety cabinets are not required for Risk Group 1 research. A. Biosafety Levels for Infectious Agents The following tables are from the CDC/NIH Biosafety in Microbiological and Biomedical Laboratories (4th Edition); http://www.cdc.gov/od/ohs/biosfty/bmbl4/bmbl4s3t.htm. Page 3 of 14 Table 1. Summary of Recommended Biosafety Levels for Infectious Agents Biosafety Level Agents Practices Safety Equipment (Primary Barriers) 1 Not known to consistently cause disease in healthy adults Associated with human disease, hazard = percutaneous injury, ingestion, mucous membrane exposure Standard Microbiological Practices None required BSL-1 practice plus: Primary barriers = Class I or II Biological Safety Cabinets (BSCs) or other physical containment devices used for all manipulations of agents that cause splashes or aerosols of infectious materials; PPEs: laboratory coats; gloves; face protection as needed BSL-1 plus: Autoclave available Primary barriers = Class I or II BCSs or other physical containment devices used for all open manipulation of agents; PPEs: protective lab clothing; gloves; respiratory protection as needed BSL-2 facility plus: 2 Limited access Biohazard warning signs "Sharps" precautions 3 Indigenous or exotic agents with potential for aerosol transmission; disease may have serious or lethal consequences Biosafety manual defining any needed waste decontamination or medical surveillance policies BSL-2 practice plus: Controlled access Decontamination of all waste Decontamination of lab clothing before laundering Dangerous/exotic agents which pose high risk of lifethreatening disease, aerosol-transmitted lab infections; or related agents with unknown risk of transmission BSL-3 practices plus: Clothing change before entering Shower on exit All material decontaminated on exit from facility Physical separation from access corridors Self-closing, doubledoor access Exhausted air not recirculated Baseline serum 4 Facilities (Secondary Barriers) Open bench top sink required Primary Barriers = All procedures conducted in Class III BSCs or Class I or II BSCs in combination with full-body, air-supplied, positive pressure personnel suit Negative airflow into laboratory BSL-3 plus: Separate building or isolated zone Dedicated supply and exhaust, vacuum, and decon systems Other requirements outlined in the text B. Biosafety Levels for Vertebrate Animal For protocols proposing work with animals and infectious agents, the IACUC, must be completed and submitted. Protocol form must be completed and signatures by Biosafety Committee must be in place before review by IACUC. Page 4 of 14 Table 2. Summary of Recommended Biosafety Levels for Activities in Which Experimentally or Naturally Infected Vertebrate Animals Are Used Biosafety Level Agents Practices Safety Equipment (Primary Barriers) 1 Not known to consistently cause disease in healthy human adults. Standard animal care and management practices, including appropriate medical surveillance programs As required for normal care of each species. Facilities (Secondary Barriers) Standard animal facility No recirculation of exhaust air Directional air flow recommended 2 Associated with human disease. ABSL-1 practices plus: Limited access Hazard: percutaneous exposure, ingestion, mucous membrane exposure. Biohazard warning signs Sharps precautions Biosafety manual 3 Indigenous or exotic agents with potential for aerosol transmission; disease may have serious health effects. Decontamination of all infectious wastes and of animal cages prior to washing ABSL-2 practices plus: Decontamination of clothing before laundering Disinfectant foot bath as needed Dangerous/exotic agents that pose high risk of life threatening disease; aerosol transmission, or related agents with unknown risk of transmission. ABSL-3 practices plus: Entrance through change room where personal clothing is removed and laboratory clothing is put on; shower on exiting All wastes are decontaminated before removal from the facility Page 5 of 14 PPE: laboratory coats, gloves, face and respiratory protection as needed. ABSL-2 equipment plus: Controlled access Cages decontaminated before bedding removed 4 ABSL-1 equipment plus primary barriers: containment equipment appropriate for animal species; Containment equipment for housing animals and cage dumping activities Class I or II BSCs available for manipulative procedures (inoculation, necropsy) that may create infectious aerosols. PPEs: appropriate respiratory protection ABSL-3 equipment plus: Maximum containment equipment (i.e., Class III BSC or partial containment equipment in combination with full body, air-supplied positive-pressure personnel suit) used for all procedures and activities Handwashing sink recommended ABSL-1 facility plus: Autoclave available Handwashing sink available in the animal room. Mechanical cage washer used ABSL-2 facility plus: Physical separation from access corridors Self-closing, doubledoor access Sealed penetrations Sealed windows Autoclave available in facility ABSL-3 facility plus: Separate building or isolated zone Dedicated supply and exhaust, vacuum and decontamination systems Other requirements outlined in the text VI. Select Agents 42 CFR Part 72 RIN 0905-AE70 “Interstate Shipment of Etiologic Agents” regulates the transfer of select agents. This rule places shipping and handling requirements on facilities that transfer or receive select agents listed in the rule that are capable of causing substantial harm to human health. Prior to transferring or receiving a select agent listed, a facility must register with the CDC through the IBC Office. The following is the CDC list of select agents: Viruses - Crimean-Congo haemorrhagic fever virus, Eastern Equine Encephalitis virus, Ebola viruses, Equine Morbillivirus, Lassa fever virus, Marburg virus, Rift Valley fever virus, South American Haemorrhagic fever viruses (Junin, Machupo, Sabia, Flexal, Guanarito), Tick-borne encephalitis complex viruses, Variola major virus (Smallpox virus), Venezuelan Equine Encephalitis virus, Viruses causing hantavirus pulmonary syndrome, Yellow fever virus Bacteria - Bacillus anthracis, Brucella abortus, B. melitensis, B. suis, Burkholderia (Pseudomonas) mallei, Burkholderia (Pseudomonas) pseudomallei, Clostridium botulinum, Francisella tularensis, Yersinia pestis Rickettsiae - Coxiella burnetii, Rickettsia prowazekii, Rickettsia rickettsii Fungi - Coccidioides immitis Toxins - Abrin, Aflatoxins, Botulinum toxins, Clostridium perfringens epsilon toxin, Conotoxins, Diacetoxyscirpenol, Ricin, Saxitoxin, Shigatoxin, Staphylococcal enterotoxins, Tetrodotoxin, T-2 toxin The following must be submitted to the IBC Office when proposing work with a Select Agent, then the IBC will submit the material to the CDC: a cover letter from the College Dean completed applicable form “Information on Select Agents…” completed applicable Laboratory Assessment Instruments Form curriculum vitae for Principle Investigator indication of the source of DNA/organism indicate assurance that there are no spores or living material present discussion of Biosecurity procedures (i.e., inventory, security) - found in Appendix I of the CDC/NIH Biosafety in Microbiological and Biomedical Laboratories, 4th ed. sketch/floor plan (not blueprints) of the lab where work will be performed. The plan should show entry, location of biosafety cabinet, incubators, freezers, autoclaves, other equipment and the location of air intake and exhaust vents. Also, a description of the air-handling system for the lab is required, (e.g., single pass or re-circulation, type of filters, method for handling safety cabinet exhaust.) The CDC may inspect the facility using a Select Agent. Once a registration number has been provided from the CDC to the University, Form EA-101 must be filled out prior to the actual transfer of agent. The form must be provided to the CDC and be retained for five years after the shipment or after the agents are consumed or properly disposed, whichever is longer. VII. IBC Procedures for the Review of Protocols and Amendments Upon receipt of a protocol, the IBC staff reviews it for completeness and notifies the investigator of any apparent problems. Each protocol is then assigned a protocol number by which the protocol will be tracked. Amendments for each protocol will be numbered sequentially upon receipt. Each new protocol and amendment is reviewed upon receipt by the IBC staff. See Appendix B for the flow of protocol and amendment reviews. Page 6 of 14 A. Committee Review of New Protocols IBC members who are involved in the protocol being reviewed will not be counted toward a quorum. Reviewers are guaranteed anonymity, which they themselves may waive. The IBC office will not disclose the name of protocol reviewers. Following each IBC review, the principal investigator is informed of the protocol status in writing. Types of Review Risk Group 1 Review - Risk Group 1 agents are not associated with disease in healthy adult human, typically DNA work with E. coli is RG1. Will be reviewed by the committee at a convened meeting. Risk Group 2 or higher Review - Risk Group 2 agents are associated with human disease which are rarely serious and for which preventive or therapeutic interventions are often available. The full committee will review these protocols. B. Review of Amendments When any revision to an approved research protocol is desired, the investigator must submit an Amendment Form. The form must be completed indicating the changes. The form should explain what changes have been made and the rationale for those changes. A revised copy of the pertinent original should also be submitted with the changes identified. A cover letter or additional information may be attached as necessary. Amendments to approved protocols may not be initiated until IBC approval has been obtained. For staff or location changes, an acknowledgementminor change letter signed by the IBC Administrator will be sent to the PI. For other changes, the amendment will be reviewed by the full IBC or the subcommittee per the procedure that the original protocol was reviewed. Once approved, the IBC Chair will sign the approval letter, with the original letter going to the PI and a copy kept in the IBC file. When adding a risk group 2 or higher agent to an approved protocol, the PI must submit with the amendment. C. Protocol/Amendment Status As part of its review of a protocol or amendment, the committee will assign a status to each protocol. A letter indicating the status will be signed by the IBC Chair and sent to the PI. That status will be one of the following: Approved - If full approval is granted, the investigator may begin the research outlined in the protocol. Protocols are approved for 5 years. Approved with stipulations - Protocol is approved as long as PI follows any stipulations the Committee indicates on the letter. The PI is NOT required to respond to this letter in writing. Examples of stipulations may include reinforcing a point to the PI, i.e., work is approved as BL1 with BL2 practices, which will include gloves, no mouth pipetting, etc. Pending - conditions (Formerly Approved with Conditions) - This status indicates that there are questions or issues, which the investigator must resolve before the protocol can receive full approval. No research may be initiated until all conditions have been met and full approval has been obtained. The PI MUST respond to all conditions within 60 days of notification. After 60 days with no response, another letter is sent by the IBC to the PI requesting a response, after an additional 30 days with no Page 7 of 14 response, the protocol or amendment is withdrawn. The PI’s response to the conditions goes back to reviewer, who will confirm the response is satisfactory and the protocol will be given full approval. All time periods are pending no unforeseen circumstances. Pending - Deferred - Protocols receiving a deferred status contain concerns of a more substantive nature such that once the investigator responds the protocol must be reviewed by the full Committee. No research can be done at this time until a satisfactory response is received and full approval has been granted. The PI MUST respond to all conditions within 60 days of. After 60 days with no response, another letter is sent by the IBC to the PI requesting a response. After an additional 30 days with no response, protocol or amendment is withdrawn. All time periods are pending no unforeseen circumstances. Reject - The Committee has major concerns with the protocol. The protocol is not justified and poses severe or unnecessary risk; protocol may have been deferred several times; the problems with the proposed protocol have not been adequately addressed. Further revisions to a rejected protocol will not be accepted. The PI may re-write the protocol with substantial changes for submission as a new protocol. Withdrawn – This designation applies to protocols or amendments that have been removed from further consideration by the IBC. This may occur because the PI failed to respond to Committee questions in the allotted time or because the PI has withdrawn the protocol or amendment for their own reasons. Terminated – The protocol is no longer active and research outlined in the protocol must not be conducted. The PI may terminate the protocol at any time by contacting the IBC Administrator. The PI may also indicate to terminate the protocol during the renewal process. If the PI fails to respond to renewal survey within the allotted time, the IBC may terminate the protocol. VIII. Protocol Renewals In accordance with federal regulations, the IBC is required to periodically review recombinant DNA research conducted at the University to ensure compliance with the NIH Guidelines. The protocol renewal process will include a cover letter and an IBC Protocol Renewal Survey, for each approved protocol assigned to the investigator. Protocol Renewal Surveys for all protocols assigned to an investigator must be completed in full and received by the IBC Office in room 130 Dyson within three weeks. Once the IBC is satisfied that the survey is complete, a renewal letter will be sent to the investigator. All time periods are pending no unforeseen circumstances. If the survey has not been submitted to the IBC Office, the IBC may send a follow-up notice for delinquent surveys. Failure to provide an adequate and timely response to the survey will result in an AUTOMATIC TERMINATION of the protocol. The IBC will send a “Notice of Termination”. In this case, if future research conducted under the protocol is requested, a new submission and approval of the protocol is required. Keep in mind that the IBC may find that additional information or revisions are needed while reviewing a new submission. Page 8 of 14 IX. Termination of a Protocol Investigators should terminate a protocol when biohazards are no longer being used. Investigators are encouraged to notify the IBC as soon as a study should be terminated. However, another mechanism for terminating a study is through the continuing review process. When a faculty member leaves the University, he or she should terminate his/her protocol(s), or notify the IBC in writing that the protocol(s) should be transferred to another investigator who will take responsibility for the research. See section on transferring a protocol to another investigator. X. Transferring a Protocol to Another Investigator When an investigator chooses to transfer his status as principal investigator on an approved protocol to another investigator, the IBC must be notified. The new investigator must be eligible to serve as Principal Investigator (See Section II). To effect this transfer, an Amendment Form should be submitted to the IBC with a statement that the protocol should be transferred to another investigator who will take responsibility for the research. Section V, Staff Group, of the Protocol Submission Form must also be completed and submitted. This amendment should be co-signed by the existing investigator and the new investigator recognizing that he/she is now responsible for the study. If the former investigator is no longer at the University, a simple statement to this effect, rather than his/her signature is sufficient. IBC staff will inform the investigator when the amendment is approved. If the IBC is notified that a PI is no longer at the University, all PI-eligible participants listed on the protocol will be contacted by email, to inquire whether they would like the protocol transferred. At this point, the protocol is suspended and the work outlined on the protocol cannot be conducted. The PI-eligible participants have 30 days to submit an amendment requesting a transfer. After 30 days, if no amendments were received, the protocol will be terminated. All time periods are pending no unforeseen circumstances. XI. Other Committees Related to the IBC Often research will require review by other committees in addition to the IBC. In these cases, copies of each Committee's approval must be cross-referenced in the other Committee's files and approval of one Committee will be contingent upon the other. Coordination of review by these committees will be done through the Office of Animal Care & Research Compliance. A. Institutional Animal Care and Use Committee (IACUC) The IACUC is charged with the responsibility for review, approval and surveillance of all research and teaching protocols involving the use of animals at Florida A&M University. This review and surveillance is conducted to assure the humane care and use of animals in these protocols. B. Institutional Review Board (IRB) The IRB is charged with the responsibility for review, approval and surveillance of all research involving human subjects carried out at Florida A&M University. This review and surveillance is conducted to assure the protection of the rights and welfare of all research subjects, including volunteers and patients. Page 9 of 14 XII. Responsibilities of Investigators It is the responsibility of the investigator to: ensure that all procedures in approved protocols are performed and/or supervised by the listed investigator or other authorized personnel (not unlisted investigators, technicians, residents, fellows or students); submit an amendment to the IBC if the investigator or other personnel have changed; provide the IBC with the appropriate information on the research protocol including initial information, notification of subsequent modifications, and terminations; ensure that no research will be initiated until IBC approval is received; carry out the protocol as approved, initiating modifications only after the IBC has approved the amendment; ensure all personnel listed on the protocol have been adequately trained in microbiological techniques and practices required to ensure safety and for procedures in dealing with accidents; enforce federal regulations regarding laboratory safety for all persons who work under his/her direction; correct work errors and conditions that may result in the release of rDNA materials or infectious agents and ensuring the integrity of the physical containment; report any adverse event, such as a work related injury or exposure to the IBC; ensure that participants, if any, employ the necessary safeguards to protect laboratory personnel, students, and the community from potential hazards posed by the project; and ensure the timely completion and submission of the renewal survey; it is the responsibility of the principal investigator to ensure that review is completed and approved by the IBC. The IBC will mail original correspondence only to the principal investigators. It is the responsibility of the investigator to ensure that copies of IBC letters are distributed to appropriate individuals (e.g. grant and contract administrators, department administrators, granting agencies, etc.). XIII. Responsibilities of the Participants It is the responsibility of the participant to: read and understand the submitted protocol; read and understand the applicable sections (for risk group and biosafety level) of the biosafety manual; to abide by the procedures in approved protocols; be adequately trained in microbiological techniques and practices; and report any adverse event, such as a work related injury or exposure to the PI. XIV. Adverse Events Any adverse event, which occurs related to an IBC Protocol, must be reported to the IBC Administrator or IBC Chair. Examples of adverse events include: work-related exposures, injuries, illnesses, laboratory accidents, any event of non-compliance, such as research conducted outside the scope of the approved protocol. If the protocol in question involves animals, the IACUC will evaluate the adverse event or handle the non-compliance. If the protocol involves animals and infectious agents, the IACUC and the IBC will handle the relevant issues jointly. Page 10 of 14 The IBC must determine if the problem, research-related accident or illness is significant to necessitate reporting to the institutional official or NIH/OBA. A. IBC requirements: Section IV-B-2-b-(7) The IBC shall report any significant problems with violations of the NIH Guidelines and any significant research-related accidents and illnesses to the appropriate institutional official and NIH/OBA within thirty days, unless the institution determines that a report has already been filed by the PI or the IBC. B. PI requirements: Section IV-B-7-a-(3) The PI shall report any significant problems, violations of the NIH Guidelines, or any significant research-related accidents and illnesses to the Biological Safety Officer (where applicable), Greenhouse/Animal Facility Director (where applicable), Institutional Biosafety Committee, NIH/OBA, and other appropriate authorities (if applicable) within 30 days. Any non-compliance with these procedures may result in the suspension of the protocol. Page 11 of 14 Appendix B. IBC Procedures for Florida A&M University IBC Protocol or Amendment is received, pre-reviewed by the IBC Administrator If protocol involves Plants, the Plant expert ex-officio member will also review, in addition to the subcommittee or full committee reviewers. If protocol involves Animals, the animal expert ex-officio member will also review, in addition to the subcommittee or full committee reviewers. Protocol is Risk Group 1 Protocol is Risk Group 2 IBC Subcommittee (two members, not involved with the protocol) will review the protocol Subcommittee has seven days to review protocol Full IBC will review the protocol Full Committee has 10 days to review the protocol Once Subcommittee or the Full Committee reviews the protocol, the IBC Administrator will contact the PI to address any issues/concerns. Renewal surveys will be sent to the PI on a regular basis. A renewal letter will be sent to the PI, once the survey is complete. Page 12 of 14 Once approved, the IBC Administrator will update the database and generate an approval letter for the Chair (Vice-Chair if Chair is not available) to sign. Original letter will be sent to PI, and a copy placed in the protocol file.