CSHEMA - Campus Safety, Health, and Environmental Management Association

CSHEMA Submits Comments on Proposed NIH Biosafety Policy, Calls for Additional Public Review

October 12, 2026—The Campus Safety, Health, and Environmental Management Association (CSHEMA) has submitted formal comments to the National Institutes of Health (NIH) regarding the Draft NIH Biosafety Policy for Research Involving Biohazards (NOT-OD-26-112), calling for significant clarification and additional opportunities for public review before the policy is finalized.

CSHEMA supports NIH's efforts to modernize biosafety oversight and establish a more comprehensive, risk-based framework. However, the Association expressed concerns that the proposed policy could substantially expand institutional responsibilities without providing the clarity, authority, resources, or implementation time necessary to ensure effective compliance.

CSHEMA's comments identify several areas of concern, including:

• Scope and Risk-Based Oversight: Clarifying which research activities fall under the policy and ensuring that oversight requirements are proportionate to actual biosafety risks, particularly for routine, low-risk research.
• Institutional Responsibilities and Resources: Ensuring that Institutional Biosafety Committees (IBCs) and biosafety professionals have appropriate authority and institutional support to fulfill expanded responsibilities.
• Transparency and Incident Reporting: Balancing public transparency with protection of sensitive research information, individual privacy, and a strong safety culture that encourages reporting of incidents and near misses.
• Implementation Timeline: Recommending a minimum 24-month phased implementation period, accompanied by clear guidance, standardized tools, training, and appropriate resources.

Given the number of unresolved questions and the potential impacts on institutions of all sizes, CSHEMA is urging NIH to release a revised draft for an additional period of public review and comment before finalizing the policy.

CSHEMA is also encouraging member institutions to submit their own comments to NIH. Institutions may endorse CSHEMA's recommendations, submit additional comments reflecting their unique research activities and institutional circumstances, or combine both approaches.

Resources for Member Institutions

To assist members, CSHEMA has developed two resources:

• Institutional Comment Letter Template: A customizable template to help institutions communicate their support for CSHEMA's recommendations and/or provide additional comments.
• Senior Leadership Briefing Document: An overview of the potential institutional impacts of the proposed NIH biosafety policy and the new U.S. Government Policy for Stopping High-Risk Life Sciences Research, designed to help institutional leaders understand the implications for research oversight, compliance, staffing, and resources.

CSHEMA encourages members to share these materials with institutional leadership, research administration, and other stakeholders and to participate in this important opportunity to shape federal biosafety policy. The deadline for comment submission is October 19, 2026.

CSHEMA's submitted comments and supporting resources are available on the NIH Biosafety Policy Resources page.

About CSHEMA

The Campus Safety, Health, and Environmental Management Association (CSHEMA) is the leading professional association for environmental health and safety in higher education. CSHEMA advances the profession through education, advocacy, collaboration, and professional development, supporting safe and healthy environments for teaching, learning, and research.