Submitted Electronically to: RE: Response to Notice of Proposed Rulemaking on Agricultural Bioterrorism Protection Act of 2002; Biennial Review and Republication of the Select Agent and Toxin

The training must also instruct each individual on the notification COGR Response to NPRM on Biennial Review & Republication of the Select Agent and Toxin List 4 requirements related to select agents and toxins. [...] (4) Each individual not approved for access to HHS and overlap select agents and toxins by the HHS Secretary or APHIS Administrator who performs administrative or oversight functions of the facility related to the transfer, possession or use of such agents or toxins on behalf of the entity ( e.g., administrative professionals, facility managers, etc.). [...] Similarly, subsection (4) calls for training any individual “who performs administrative or oversight functions of the facility related to the transfer, possession or use of such agents or toxins on behalf of the entity (e.g., administrative professionals, facility managers, etc.).” USDA should definitively specify the classes and duties of personnel to whom such training should be provided. [...] We suggest the following language: Each individual not approved for access to HHS and overlap select agents and toxins by the HHS Secretary or APHIS Administrator who performs administrative tasks related to ordering, storing, or securing the transfer, possession or use of such agents or toxins on behalf of the entity. [...] COGR Response to NPRM on Biennial Review & Republication of the Select Agent and Toxin List 5 Conclusion COGR and its member institutions understand the need to ensure that select agents and toxins are possessed, used, and transferred in a safe and secure manner.