Plant Research and Greenhouses

Regulated or Restricted Plant Pests

The movement, use, possession, or release of exotic or potentially harmful plant-associated arthropods, biological control agents, plant pests, plant pathogens, noxious weeds, and invasive plants are regulated by the State of Florida http://www.doacs.state.fl.us/onestop/plt/entnempath.html as well as the USDA APHIS http://www.aphis.usda.gov/plant_health/index.shtml. The use of these regulated materials will require a Biological Agent registration (http://www.ehs.ufl.edu/bio/Files/BiologicalAgent.pdf) with the Biosafety Office in addition to the appropriate state or federal permits. Note that some plant pathogens are controlled for export and regulated as select agents.

The current list can be found at National Select Agency Registry Website .

There are additional plant pathogens not on the select agent list that are also regulated for export. Please see the Bioagent Export Control List.


Containment/Handling Practices for Regulated Experiments with Plants and Plant-Associated Organisms

Care must be taken to

  • avoid the unintentional transfer of plant genes, recombinant or otherwise, to other plants
  • minimize unanticipated, harmful effects to organisms or the environment outside the experimental site/facility
  • avoid the inadvertent spread of pathogens or noxious weeds to crops or native vegetation
  • prevent the introduction of unwanted exotic organisms into a new habitat

Containment can come from physical or biological means. Examples of physical containment are the use of plant growth chambers or greenhouses, or catch trays under plants to prevent soil contamination. Examples of biological containment include the removal or inactivation of plant reproductive structures (pollen and seed), timing of experiments so that plant-associated microorganism(s) under study are not viable in the outside environment, and the exclusion of vectors or fomites that spread plant pathogens.

Since plant research usually (but not always) does not pose a human health hazard, biosafety principles are designed instead to protect the natural and agricultural environment. Four biosafety level designations and associated safety practices for plant research exist: BL1-P, BL2-P, BL3-P, and BL4-P. No BL4-P experiments are permitted at the University of Florida.

A risk assessment that factors in the

  • specific organism(s) under study
  • geographic, ecological, and agricultural environment surrounding the study site
  •  physical/mechanical barriers available, and
  • scientifically accepted culture techniques

should be conducted to determine what level of containment/handling practices are required.  Physical and biological containment requirements spelled out in NIH Guidelines Appendix P http://oba.od.nih.gov/oba/rac/Guidelines/APPENDIX_P.htm apply to laboratories, growth chambers and greenhouses; these facilities will be inspected by the Biosafety Office as part of rDNA project approval and/or continuation.

All genetically-altered plants and plant-related organisms that will be grown or released outside need prior federal approval (see regulations section below).

Although it emphasizes containment principles for transgenic plants and associated organisms, the book “A Practical Guide to Containment, Greenhouse Research with Transgenic Plants and Microbes”, available on line at Information Systems for BioTechnology, is an excellent resource.


Plant-Related Recombinant DNA Research

Research with genetically engineered plants, genetically engineered plant-associated microbes, and genetically engineered plant-associated macroorganisms (arthropods and nematodes) is covered by the NIH Guidelines for Research Involving Recombinant DNA Molecules, section P http://oba.od.nih.gov/oba/rac/Guidelines/APPENDIX_P.htm. Appendix P supersedes Appendix G (Physical Containment, laboratories) when the research plants are of a size, number, or have growth requirements that preclude the use of containment conditions described in Appendix G for laboratory conditions.

These guidelines are in place to prevent the accidental transmission of a recombinant DNA-containing plant genome (either nuclear or organelle genetic material) or the release of recombinant DNA-derived organisms associated with plants into the environment.

All recombinant DNA research, including that with plants and plant-related organisms must be registered with our Biosafety Office.

Registration forms can be found at Registration Forms


State and Federal Regulations

Plant research involving noxious weeds, invasive plants, and certain plant pests, plant-associated microbes, and plant diseases (such as citrus canker) are regulated by the Florida Dept. of Agriculture & Consumer Services, especially when the import, export, or transfer of these or materials is required. Contact the Division of Plant Industry for rules and regulations.

The USDA-APHIS also regulates plant pests, plants and plant products, and the movement, importation, and field release of genetically-engineered plants and arthropods. See the detailed APHIS website for information, applications, permits, and notification documents.  The Biosafety Office and/or IBC will request current versions of field release approvals as part of rDNA or field release project approval or continuation. In addition to the USDA APHIS, the State of Florida Division of Plant Industry, the USDA Biotechnology Regulatory Service, the FDA (for genetically altered food crops), and the EPA (for genetically modified organisms with pest control activity) EPA, for plant incorporated protectants may also regulate research with transgenic plants and plant-associated organisms.

The following websites provide an overview of the regulatory process and related links:

Florida Dept. of Ag. & Consumer Services, Dept. of Plant Industry (FDACS–DPI)

USDA Biotechnology Regulatory Service (BRS) – 7CFR Part 340

USDA Plant Protection & Quarantine (PPQ) – 7 CFR Part 330

NIH Guidelines Appendix P (rDNA, transgenics, GMOs)

APHIS PPQ Containment Guidelines

FDA, for plant made pharmaceuticals or biotech foods and feeds

EPA, for plant incorporated protectants

Video links from the “Regulatory Biosafety for Plant Research” symposium held on April 2010 at UF are available below for reference

Regulation of Agricultural Biotechnology Products in the U.S

PPQ Plant Pest and Biocontrol Permitting Policy 

State of Florida Perspective on Plant Pest Permitting