Principal investigators must first obtain a Biological Use Authorization (BUA) from the Institutional Biosafety Committee (IBC) in order to conduct research with the following materials and/or strategies:
- Microorganisms that cause disease in humans, animals or plants
- Human or non-human primate primary cells or tissues
- Human or non-human primate feces
- Recombinant DNA techniques requiring IBC approval as described by the NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules
- Cloning genes that encode molecules toxic to vertebrates
- Animal experiments covered by the NIH Guidelines
- Biological Select Agents and Toxins
BUA Approval Process
The IBC meets on the second Wednesday of the month during the academic year, and during the summer as necessary. Agenda items are sent out one week before the IBC meets.
Principal investigators are responsible for completing the BUA form and assessing the risks associated with the biological materials and experimental procedures. The biosafety officer (BSO) reviews applications to ensure that the materials and procedures are described with enough detail for the IBC to evaluate containment measures.
The BSO also meets with the PI or their designee to review the lab spaces listed in the BUA.
BUA Lab Space Review Checklist
If the IBC approves the BUA as-is, the BSO emails the PI the letter of approval.
Otherwise, the biosafety officer contacts the principal investigator (PI) with a summary of questions or additional recommendations.
Letters of approval contain the BUA title, tracking number, expiration date, biosafety level(s) of containment, applicable section(s) of the NIH Guidelines, training requirements, and any occupational health recommendations or requirements. Letters of approval are forwarded to the IACUC Coordinator when the BUA is associated with an IACUC protocol.
BUAs are approved for 3 years.
CHANGES TO APPROVED BUA APPLICATIONS
Changes that increase the risks of the project are reviewed and approved by the IBC at the regular monthly meeting. Highlight changes and new information within the originally approved BUA, and update the training roster and biosafety cabinet certification dates.
Provide the biosafety officer with the name, title (graduate student researcher, undergraduate, etc.), and date of BBP training within 12 months by email.
Group member names may be also added or removed directly within the Google Document BUA form that is shared with the biosafety officer.
Registering Work with Human Cell Lines
Human cell lines that are derived from apparently healthy donors and screened for a panel of the most common bloodborne pathogens are considered well characterized. Well characterized human cell lines are accompanied by a Certificate of Analysis from the vendor indicating that the cells have been screened and found to be negative for, at a minimum, hepatitis B virus, hepatitis C virus, and the human immunodeficiency virus. The Certificate of Analysis documents reduced concerns for the presence of bloodborne pathogens by ruling out the main pathogens that have been encountered in hospital settings. The panel of bloodborne pathogens is specific to the vendor and varies slightly.
Principal investigators register their work with well characterized human cell lines with the IBC via the biosafety officer using the standard BUA form. Use of such cell lines does not require IBC review or approval before work begins.
The California Department of Public Health does not designate well characterized human cell lines as medical waste.
• See California Health and Safety Code Sections 117600 – 118360, specifically, 117700 (a) and (b), for biological materials excluded as medical waste.
The Occupational Safety and Health Administration exempts well characterized cell lines from the Bloodborne Pathogens Standard.
• OSHA Standard Interpretation issued 1994: https://www.osha.gov/laws-regs/standardinterpretations/1994-06-21
For established tumor cell lines, human or NHP origin does not intrinsically make them medical waste unless there is information about contamination with pathogens or integration of non-defective pathogenic viral sequences.
Be advised that you likely need an export license prior to shipping research materials internationally. Please contact the campus Export Control Officer, email@example.com, for assistance.
Please note that you may also need approval from Institutional Committees that oversee the ethics of research with human subjects, animals subjects, and/or stem cells. These Committees are administered by Research Integrity within the Office of Research.