The use of siRNA or silencing RNA (and other RNA interference methods) has become an increasingly popular method for the evaluation of consequences of the expression and/or lack of expression of a particular gene and its resulting gene product. The NIH Guidelines makes an exemption for research with certain low-biosafety-risk synthetic nucleic acid molecules. Specifically, synthetic nucleic acids molecules that meet the following criteria will be exempt:
Those synthetic nucleic acids that:
- Can neither replicate nor generate nucleic acids that can replicate in any living cell (e.g., oligonucleotides or other synthetic nucleic acids that do not contain an origin of replication or contain elements known to interact with either DNA or RNA polymerase), and
- Are not designed to integrate into DNA, and
- Do not produce a toxin that is lethal for vertebrates at an LD50 of less than 100 nanograms per kilogram body weight.
An example of an exempt molecule would be research with a synthetic short-interfering RNA (siRNA) that targets an HIV viral protein required for transcription activation, even if this siRNA is injected into animals or used in cell culture. Please call the IBC Office if you have any questions.
For Clinical research, however, Section III-C-1 of the amended NIH Guidelines covers human gene transfer experiments. Registration with the IBC is required if research involves the deliberate transfer into human research participants of either:
- Recombinant nucleic acid molecules, or DNA or RNA derived from recombinant nucleic acid molecules, or Synthetic nucleic acid molecules, or DNA or RNA derived from synthetic nucleic acid molecules, that meet any one of the following criteria:
- Contains more than 100 nucleotides; or
- Possesses biological properties that enable integration into the genome (e.g., cis elements involved in integration); or
- Have the potential to replicate in a cell; or
- Can be translated or transcribed.
The above criteria are designed to capture synthetic nucleic acid agents that share common characteristics with current gene transfer agents that are delivered by vectors.
Please call the IBC Office if you have any questions.
For additional information, see FAQs on Institutional Biosafety Committee (IBC) Administration – April 2024