IBC Review Process

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Last Updated: Sep 03, 2026, 11:12 AM

This page explains how the IBC review process works, how to submit an MUA, amendment, or renewal, and what to do if an incident occurs. If you are unsure whether your research requires IBC approval, start with the FAQ below.

Do I need IBC Approval?

If your work involves any of the materials listed on Policy 310 (Activities requiring an MUA), a Memorandum of Understanding and Agreement (MUA) must be submitted to the IBC for review and approval before work begins. This requirement applies to all SIUC faculty, staff, students, and volunteers working with regulated biological materials, regardless of funding source.

No work may begin until the PI receives formal written approval from the IBC.

Projects involving human subjects or vertebrate animals require additional IRB or IACUC approvals. All applicable approvals and permits must be in place before work begins.

Certain projects may also require a health surveillance plan for laboratory personnel. The BSO will advise whether this applies to your work during the MUA review process.

If you are unsure whether your work requires an MUA, contact the IBC at ibc@siu.edu before work begins.

How MUAs are Reviewed?

Once a submitted MUA is received, it undergoes an initial administrative pre-review. The PI will be notified of any issues or changes needed at this stage. After pre-review is complete, the IBC Chair, in consultation with the Biological Safety Officer (BSO), assigns the submission to one of three review pathways (full committee review, chair review, or administrative review) based on the nature of the research and NIH Guidelines.

Full Committee Review

The committee reviews and votes on these submissions at a scheduled meeting with quorum present. Full committee review is required for:

  • Work with recombinant Risk Group 2 or higher agents
  • Work with recombinant human-derived materials and r/sNAs
  • Human gene transfer protocols
  • Select Agents and Toxins
  • Dual Use Research of Concern (DURC)
  • r/sNA research under NIH Guidelines Sections III-A through III-D
  • Renewals or amendments involving a change in PI, increase in risk group, change in biosafety level, significant protocol changes, or addition of Select Agents or DURC
  • Any protocol for which a committee member requests full review

Chair Review

The Chair, in consultation with the BSO, may review and approve specific types of MUAs without convening the full committee. Chair review applies to:

  • New submissions involving only NIH Guidelines Sections III-E or III-F experiments
  • Renewals or amendments with minor changes, such as minor procedural updates, minor changes in species or organisms, or a change in lab location

All Chair-reviewed approvals are reported at the next scheduled committee meeting. At any point, the Chair, BSO, or any committee member may call for full committee review.

Administrative Review

Limited to minor administrative updates that do not affect the scientific scope or risk level of the project, including:

  • Changes in key personnel other than the PI
  • Updates to contact information or funding sources
  • Minor corrections to the MUA title or text

Administrative reviews are handled by the IBC Coordinator in consultation with the Chair and reported at the next committee meeting.

Renewing an Existing MUA

Approved MUAs are valid for three years. To maintain active status beyond the initial approval period, the PI must submit the MUA for de novo renewal (a full resubmission reviewed under the same process as a new MUA). It is the PI's responsibility to initiate the renewal process.

If minor changes to the protocol are needed at renewal, submit an amendment along with the renewal. If major changes are involved, the IBC Chair and BSO will determine the appropriate review path.

Amending an MUA

Modifications of the experimental protocol require that an amendment is submitted for review and approval. To submit an amendment, email ibc@siu.edu with a copy of the updated MUA and a memo detailing the requested changes.

Frequently Asked Questions (FAQ)

How do I know what biosafety level my research is?

Biosafety levels (BSL1–BSL4) reflect the risk posed by the biological agents involved and determine the containment practices and facilities required. The CDC/NIH publication Biosafety in Microbiological and Biomedical Laboratories (BMBL) is the primary reference. As a general guide:

  • BSL1 — agents not known to cause disease in healthy adults; standard laboratory practices apply
  • BSL2 — agents associated with human disease of moderate severity; limited access and protective equipment required
  • BSL3 — agents that may cause serious or lethal disease via inhalation; requires specialized facilities and procedures
  • BSL4 — agents posing high risk of life-threatening disease with no available vaccine or therapy; requires maximum containment

The PI is responsible for conducting an initial risk assessment and determining the appropriate containment level before submitting an MUA. The IBC independently reviews containment levels as part of its assessment.

SIUC does have any BSL3 or BSL4 labs. Contact the BSO before planning any BSL3 or BSL4 work.

Do I need IBC approval even if I am not funded by NIH?

Yes. SIUC policy requires review and approval for all IBC regulated activities regardless of funding source.

How long does the review process take?

Timelines vary by review type. Full committee review depends on the meeting schedule, submissions must be received at least 2 weeks in advance of a scheduled meeting with quorum. Chair review is generally faster but still requires pre-review and any requested revisions to be addressed before approval is issued. Plan accordingly and submit your MUA well before your intended start date. For additional information on meeting dates and required submission deadlines, email ibc@siu.edu.

Can I start work while my MUA is under review?

No. No work may begin until the PI receives formal written approval from the IBC. This applies regardless of the review category assigned to the submission.

When do I amend my MUA versus submitting a new one?

Submit a new MUA when the research is substantively different from the approved project. For example, different aims, a different biological system, or work that falls under a different NIH Guidelines category. Submit an amendment when the core research remains the same but specific details have changed. When in doubt, contact the IBC.

What is a Select Agent and does it require additional steps?

Select Agents are biological agents and toxins identified by the federal government as posing a significant threat to public, animal, or plant health. Work with Select Agents requires full committee review by the IBC and separate registration with the CDC/USDA Federal Select Agent Program.

SIUC does not currently approve MUAs that include the use of Select Agents. Contact the BSO before acquiring or using any Select Agent.

Does my project require health surveillance for lab personnel?

Certain projects may require a health surveillance plan for laboratory employees. The MUA submission process includes a section for health surveillance information, and the IBC will advise whether any additional documentation is necessary.

Where can I find required biosafety training?

All personnel listed on an active IBC-approved MUA must complete two categories of training before beginning any IBC regulated activities. Both categories of training must be kept current throughout the life of the project.

1. Programmatic Training (CITI)

SIUC uses the Collaborative Institutional Training Initiative (CITI) for online programmatic training. The following modules are required for all personnel listed on an MUA:

  • Initial Biosafety Training (all individuals working on a project) — covers biosafety principles, risk assessment, containment practices, and personal protective equipment
  • NIH Recombinant DNA Guidelines (for projects involving r/sNA) — covers the scope and requirements of the NIH Guidelines.

Additional CITI modules may be required depending on the nature of the research (e.g., Animal Biosafety, Shipping and Transport of Regulated Biological Materials, Human Gene Transfer). CITI training must be renewed every three years by completing the Biosafety Retraining module.

To complete CITI training:

  1. Go to citiprogram.org and log in or create an account
  2. Affiliate with Southern Illinois University Carbondale
  3. Add the required course(s) to your learner profile
  4. Complete all assigned modules and download your completion report

2. Laboratory-Specific Training

In addition to CITI, all personnel must receive laboratory-specific training provided by the PI or a qualified designee before beginning work. This training must cover the specific hazards, agents, procedures, and safety practices described in the MUA and cannot be fulfilled by online coursework alone.

The PI is responsible for ensuring all lab personnel are appropriately trained. 

For additional training requirements, including chemical and biological lab safety, bloodborne pathogens, and occupational safety, see the ORC's Training Resources page. Additional training is also offered through the Center for Environmental Health and Safety (CEHS).

How do I report a biosafety incident or concern?

In an Emergency

If an incident poses an immediate threat to health or safety, follow emergency response procedures first. IBC reporting does not replace emergency response or medical treatment — those take priority.

SIUC's Center for Environmental Health and Safety also has its own incident reporting and laboratory requirements that must be followed. 

Reporting an Incident to the IBC

All incidents involving IBC-regulated activities must be reported to the IBC. An incident includes any unplanned event (such as an exposure, spill, injury, near miss, equipment failure, loss or theft of materials, or suspected noncompliance) that results in or could result in harm to personnel, the public, or the environment. See IBC Policy 500 for additional information.

The PI is responsible for ensuring incidents are reported. In the PI's absence, a supervisor or lab personnel must submit the report.

How to Report

SIUC will not tolerate retaliation against individuals who report violations or concerns in good faith.

What Happens After a Report

The IBC Chair, in consultation with the ORC and BSO, will conduct an initial appraisal to assess the nature and severity of the concern. If immediate risk is present, steps will be taken to protect personnel. Confirmed noncompliance may result in suspension or termination of IBC approval, additional corrective action, or mandatory reporting to external agencies including the NIH. The person(s) named in a complaint will be notified and given an opportunity to respond before any determination is made. Investigation details remain confidential to the extent possible.