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Tips for ongoing compliance
Now you have EPA Consent Document (Contained use: GMM (microorganisms) or EPA Letter of agreement (Contained use: GMO (Plants/Animals)...... What next?
- File your consent documents in a safe place and have at hand for future lab inspections.
- Follow the additional conditions on the consent document/Letter of agreement to meet required containment measures.
- File SOPs and Risk Assessments in a safe place so they are at hand for reference by lab members.
- Ongoing training of new staff (SOPs section for example) and maintain staff training record.
- Routine equipment maintenance and servicing especially Autoclaves and Safety Cabinets. The frequency that the EPA recommends for the use of control measures (spore strips/ ampoules) is at least monthly to ensure that inactivation methods remain adequate and effective. These validation results should be made available to the EPA on request. Please see an example of mothly-inactivation-log.
- Inactivation records of waste should be retained by each GMM/GMO user and made available for inspection by EPA on request. Please see an example of an Autoclave run log
- Common storage areas for GMM stocks (cold room, fridges, freezers) should be maintained in a clean and tidy condition and all GMM stocks should be logged.
- All GMM/GMO users are required to report annually to the EPA. Complete an Annual Report for your GM work and include details of any changes to the register, corresponding Risk Assessments, containment measurements or changes in waste disposal.