VC-LEG-0100 — Biocontainment & Controlled-Botanical Compliance Policy
The binding legal framework governing how GreenWorld Sector-7 grades, contains, audits, records, and — when required — reports the cultivation and handling of controlled botanicals across the GCL containment spectrum.
1. Purpose
1.1. This Policy establishes the mandatory legal-compliance obligations governing the cultivation, propagation, research, storage, transport, and disposal of Controlled Botanicals and their derived compounds at the Sector-7 Arboretum Complex. It exists to ensure that every activity carried out under the authority of the Directorate is defensible against the governing frameworks set out in Section 3, and that any failure of containment is met with a pre-defined, lawful, and timely response.
1.2. This Policy is the controlling legal instrument for biocontainment. Where an operational procedure (including any SOP) conflicts with this Policy on a matter of legal obligation, this Policy governs. Where this Policy is silent on operational method, the relevant SOP governs.
2. Scope
2.1. This Policy applies to all personnel, contractors, secondees, and automated agents (including CHLORA) acting within or on behalf of GreenWorld Sector-7, and to every specimen, cutting, seed, spore, extract, and dataset within the facility perimeter or in lawful off-site custody.
2.2. Defined Terms. Capitalized terms used in this Policy have the meanings assigned below.
| Defined Term | Meaning |
|---|---|
| Controlled Botanical | Any specimen, cultivar, propagule, or derived compound assigned a containment grade of GCL-2 or higher, or otherwise scheduled under the CBPA. |
| Containment Grade / GCL | The Grade of Containment Level (GCL-1 through GCL-4) assigned to a specimen under the GCL Grading & Containment Standard, GCL-1 being benign and GCL-4 being lethal, aggressive, or self-propagating. |
| Bio-Vault | A graded Containment Sphere or vault providing physical and atmospheric isolation appropriate to the assigned Containment Grade. |
| Notifiable Event | Any breach, exposure, escape, or loss of custody meeting the thresholds in Section 8.2 that triggers an external reporting obligation. |
| Custody Chain | The unbroken, logged record of accountable custody for any Controlled Botanical or derived compound from origination to disposal. |
| Designated Authority | The external regulator competent for a given framework, as listed in Section 3. |
3. Governing Frameworks
3.1. GreenWorld Sector-7 attests compliance against the following frameworks. The Compliance Officer maintains the authoritative posture register; the abridged mapping is published at Legal & Compliance → Compliance Posture.
| Framework | Short Form | Designated Authority | Core Obligation Imposed | Assessment |
|---|---|---|---|---|
| Sector Biocontainment Directive | SBD-7 | Sector Bioregulatory Authority | Mandatory containment grading and physical isolation proportionate to hazard. | Annual + event-driven |
| Controlled Botanicals & Phytotoxin Act | CBPA | Office of Phytochemical Control | Scheduling, custody chain, and export licensing of toxins and dual-use compounds. | Semi-annual |
| GCL Grading & Containment Standard (rev 4) | GCL-STD | Interbureau Biosafety Board | The GCL grading mandate and per-grade containment requirements (Section 4). | Annual |
| Hazardous Specimen Transport Protocol | HSTP-9 | Sector Transit Authority | Containment-grade transport casing and manifest control for off-site movement. | Annual |
| Occupational Phytotoxin Exposure Regulation | OPER | Sector Worker Safety Board | Exposure monitoring, medical surveillance, and PPE attestation for personnel. | Annual |
| Dual-Use Research of Concern Code | DURC-B | Directorate Ethics Council | Institutional review and authorization for weaponized-grade research. | Per-protocol |
4. Control Requirements by GCL Level
4.1. The following controls are mandatory and non-waivable except by joint written authorization of the General Counsel and the Chief Botanical Officer. Each row is independently auditable.
| Grade | Character | Containment | Access Control | Handling Rule | Telemetry | Audit Interval |
|---|---|---|---|---|---|---|
| GCL-1 | Benign ornamentals & food cultivars | Open greenhouse zone | General staff | Single-person | Routine PhytoSense | Annual |
| GCL-2 | Irritant / mild phytotoxin producers | Sealed zone, negative pressure | Badged cultivar staff | Single-person + PPE | Continuous VOC + turgor | Semi-annual |
| GCL-3 | Hazardous toxin / invasive growth | Containment Sphere, airlocked | Containment-qualified, logged | Two-person rule | Continuous + fluorescence alarm | Quarterly |
| GCL-4 | Lethal / aggressive / self-propagating | Hardened Bio-Vault, double airlock, kill-loop | Directorate-authorized roster only | Two-person + Venus Sentinel standby | Continuous + redundant sphere telemetry, no single point of failure | Monthly + spot |
5. Authorization & Custody
- 5.1. Every Controlled Botanical shall have a single accountable custodian of record at all times; custody may not lapse to "unassigned."
- 5.2. Custody transfer (including to field crews and to automated handling) shall be logged in the Mycelial Data Fabric with timestamp, transferor, transferee, and Containment Grade.
- 5.3. Compound extraction from any GCL-3 or GCL-4 specimen requires a batch authorization tied to a Toxin Yield Reactor batch record and an export/use justification under the CBPA.
- 5.4. Off-site movement requires a HSTP-9 manifest, containment-grade transport casing, and a return-of-custody reconciliation upon arrival.
6. Recordkeeping & Retention
6.1. Records are the evidence of compliance; an unrecorded control is a failed control. All records below are maintained in the MDF under the Data Stewardship & Classified Records Standard with immutable audit logging.
| Record Class | Contents | Retention | Classification | Custodian |
|---|---|---|---|---|
| Custody Chain Ledger | Origination, transfers, grade history, disposal | Life of specimen + 25 years | INTERNAL | LEG-REG |
| Containment Integrity Logs | Sphere/vault telemetry, alarms, attestations | 10 years | INTERNAL | OPS-CON |
| Extraction Batch Records | Reactor batch, yield, compound disposition | 15 years | CHLOROPHYLL-EYES-ONLY | OPS-PSB |
| Audit & Findings Files | Internal/external audit reports, remediation | 10 years | INTERNAL | LEG-REG |
| Notifiable-Event Dossiers | Incident record, notifications, regulator correspondence | Permanent | CHLOROPHYLL-EYES-ONLY | General Counsel |
| Exposure & Surveillance Records | OPER medical surveillance and PPE attestations | Career + 40 years | RESTRICTED (medical) | HR / Occupational Health |
7. Audit Cadence
7.1. Compliance is verified on a layered cadence combining continuous automated assurance, scheduled internal audit, and periodic external assessment by the Designated Authorities.
| Layer | Performed By | Cadence | Scope | Output |
|---|---|---|---|---|
| Continuous assurance | CHLORA + PhytoSense Mesh | Real-time | Containment telemetry, access events, drift | Auto-finding / Tier alarm |
| Internal control audit | LEG-REG compliance officers | Per GCL interval (§4) | Control sampling against this Policy | Findings register entry |
| Management compliance review | General Counsel + Director of Ops | Quarterly | Posture, open findings, residual risk | Attestation to CBO |
| External assessment | Designated Authorities | Per framework (§3) | Framework-specific obligations | Certificate / conditions |
| Directorate spot inspection | Office of the CBO | Unannounced | Any control, any time | Directorate directive |
8. Breach-Notification Legal Obligations
8.1. A Notifiable Event triggers two parallel clocks: the operational response under SOP VC-SOP-0401 (Containment Breach Emergency Response), and the legal notification obligations in this Section. The two run concurrently and independently; operational containment does not pause the legal clock.
8.2. Notification thresholds. The following constitute Notifiable Events:
- Any confirmed breach of a GCL-3 or GCL-4 Containment Sphere or Bio-Vault.
- Any escape, or suspected escape, of a Controlled Botanical beyond the facility perimeter.
- Any personnel phytotoxin exposure requiring medical intervention (OPER reportable).
- Any loss of custody or unaccounted-for GCL-3/4 specimen or scheduled compound.
- Any unauthorized access to a GCL-4 roster-controlled specimen.
- Any breach of CHLOROPHYLL-EYES-ONLY classified containment data (joint with VC-LEG-0300).
8.3. Notification clock. Times run from the moment the event is confirmed by the Watch Commander or CHLORA.
| Step | Obligation | Deadline | Responsible |
|---|---|---|---|
| 1 | Internal report to General Counsel & CBO | Immediate (≤ 15 min) | Watch Commander |
| 2 | Preservation hold on all related records (litigation hold) | ≤ 1 hour | General Counsel |
| 3 | Initial notification to Designated Authority | ≤ 24 hours | Compliance Officer |
| 4 | Worker-safety notification (if OPER reportable) | ≤ 24 hours | Risk Counsel |
| 5 | Written incident report to regulator(s) | ≤ 72 hours | General Counsel |
| 6 | Root-cause & corrective-action filing | ≤ 30 days | LEG-REG + OPS-CON |
9. Enforcement & Penalties
9.1. Violations of this Policy are graded and met with proportionate internal consequence, independent of any external regulatory sanction the Designated Authorities may impose.
| Severity | Example Violation | Internal Consequence |
|---|---|---|
| Administrative | Late or incomplete record entry, no containment impact | Documented coaching; record correction |
| Serious | Single-person handling of a GCL-3 specimen; missed audit | Access suspension; mandatory retraining; written warning |
| Grave | Unauthorized GCL-4 access; suppressed Notifiable Event | Immediate revocation of access; referral for dismissal; personal liability |
| Catastrophic | Willful release or sabotage of a Controlled Botanical | Dismissal; full indemnity claw-back; referral to authorities and external counsel |
9.2. Internal penalties are recorded in the employee file and, where personal liability attaches, reconciled against indemnity under VC-LEG-0400.
10. Revision History
| Rev | Date | Author | Summary of Change | Approved |
|---|---|---|---|---|
| A | 2087-03-02 | T. Mandrake | Initial issue covering SBD-7 and GCL grading mandate. | GC |
| B | 2088-05-19 | T. Mandrake | Added CBPA custody-chain and export-licensing obligations. | GC |
| C | 2089-02-11 | A. Datura | Restructured Section 8 to dual-clock model; aligned with VC-SOP-0401. | GC · CBO |
| D | 2089-09-30 | T. Mandrake | Added GCL-4 standing legal condition and Directorate spot-inspection layer. | GC · CBO |
| E | 2090-01-15 | A. Datura | Updated framework table to GCL-STD rev 4; tightened notification deadlines. | GC · CBO |