University of Wisconsin-Madison

Policy Number: 2009-036 [PDF]

Adoption Date: 01/09/2009

Effective Date: 01/09/2009

Policy for Veterinarian Access to Select Agent Animal Facilities

Adopted by UW-Madison Biosecurity Task Force on January 14, 2009

Background: The Select Agent Program imposes rigorous security measures limiting access to Select Agents and Toxins only to approved individuals. These are federal regulations that must be strictly enforced. According to 42 CFR Part 73.10.b the definition of access is as follows:

An individual will be deemed to have access at any point in time if the individual has possession of a select agent or toxin (e.g., ability to carry, use, or manipulate) or the ability to gain possession of a select agent or toxin.

The university is, at the same time, subject to USDA and OLAW requirements that necessitate unlimited access for veterinarians to areas containing animals. The intent of this policy is to reconcile these various regulations.

Individuals Covered: This policy applies to all veterinarians and approved laboratory staff working in animal facilities registered in the Select Agent Program by the University.

Policy: The following steps have been enacted to keep the university in compliance with regulations:

• All veterinarians who will need to handle animals in SA animal facilities must be registered with the Select Agent Program through the University and approved by the Centers for Disease Control and Prevention (CDC)/Department of Select Agents and Toxins (DSAT).
• CDC/DSAT-approved veterinarians will be issued SmartCards that will provide the ability to pass through the first designated SA security point (biometric reader) leading to SA animal areas. The PI or an approved lab member will know when a veterinarian is approved for access to SA facilities by the veterinarian's ability to pass through this barrier.
• Approved veterinarians will not be issued keys to the secondary doors leading to the actual animal rooms. In all cases they will be accompanied by a knowledgeable member of the research staff. This is an important limitation and is based on biosafety concerns. The agents used in these facilities pose a significant risk to individuals and the surrounding community. Staff members working in these rooms require a great deal of training before they are allowed to enter the rooms unescorted and it is not practical for veterinarians to spend the time to gain the necessary expertise in these facilities.
• Unapproved veterinarians can be escorted as a visitor by a knowledgeable and CDC/DSAT-approved member of the research staff. However, unapproved veterinarians may only observe animals.
• To balance these restrictions on the veterinarians the PIs must make available on short notice a CDC/DSAT-approved member of their research staff who will accompany the veterinarians into the registered rooms. An up-to-date contact list will be provided by the PIs to the Research Animals Resource Center in order to ensure that access can be obtained within a reasonable timeframe (e.g., within a few hours on a non-emergency basis).

Prepared by: Jeff Zebrowski

Reference Minutes: 01/09/2009