Controls Over Select Agents

Develop and implement guidance that details how inspectors should document their justifications for determinations that entities complied with Federal regulations. Specifically, APHIS guidance should: (1) describe the information reviewed that led to a pass determination of compliance; (2) define the meaning of pass statements, fail statements, non-applicable statements, and not assessed determinations.

Develop and implement controls to periodically review a sample of inspections completed by inspectors to ensure all conclusions and responses are adequately supported and accurate.

Establish oversight controls, such as a tracking report, to monitor the status of registered entities' progress to implement corrective actions. Establish procedures APHIS personnel should take to bring registered entities into compliance when corrective actions have not been timely resolved.

Train personnel on how to implement the new guidance established in Recommendation 6 through 8.

Establish procedures to report all notifications of all theft, loss, and releases that meet APHIS' definition of theft, loss, and release in APHIS' annual report to Congress.