As part of the Select Agent registration process, ALL individuals who work with select agents or have direct access to select agents must successfully complete a security risk assessment conducted by the FBI. The security risk assessment (SRA) is coordinated through the Office of Biosafety. Individuals will be granted access to select agents or toxin laboratories until approval has been granted by the CDC. The SRA authorization is valid for a maximum of five (5) years.
Individuals who do not have SRA authorization (i.e. visitors or vendors) must be escorted by an SRA-authorized individual. The SRA-authorized escort will confirm with the Office of Biosafety that the necessary training and medical certifications are current on the non-authorized individual prior to escorting this individual into the select agent or toxin laboratory. Employees escorting an unauthorized individual must receive prior approval from the Office of Biosafety before escorting each individual into the BSL-3 facility. In accordance with the select agent rule, the escort must maintain control of the escortee at all times. Individuals classified as "restricted persons" by the Attorney General will not have access to select agent or toxin areas.
A restricted person is any individual who:
- has been convicted in any court of a crime punishable by imprisonment for a term exceeding 1 year;
- is a fugitive of justice;
- is an alien illegally or unlawfully in the United States;
- has been adjucated as a mental defective or has been committed to any mental institution;
- is an alien (other than alien lawfully admitted for permanent residence) who is a national of Cuba, Iran, Iraq, Libya, North Korea, Sudan or Syria, or any other country to which the Secretary of State, pursuant to applicable law, has made a determination (that remains in effect) that such country has repeatedly provided support for acts of international terrorism; or
- has been discharged from the Armed Services of the United States under dishonorable conditions.
Security Risk Assessment Procedures:
- PI is responsible for notifying the Office of Biosafety that individuals need to be added or removed from the University's registration.
- The Office of Biosafety will coordinate with the Tulane University Police to:
- Complete FD-961 Form and return it to the Office of Biosafety, this form can be obtained by contacting the Office of Biosafety.
- Take two sets of fingerprint cards to be sent to the Attorney General.
- The Office of Biosafety submits this information on the appropriate forms to the Centers for Disease Control (CDC).
- The CDC issues unique identifying numbers for each registered individual and sends that information to the Office of Biosafety.
- The Office of Biosafety submits the fingerprint cards and FD-961 Form to the Attorney General.
- The Office of Biosafety notifies the supervisor and person seeking registration when their approval is received. Until that time, the individual may not be in areas where select agents are stored or used unless accompanied at all times by an SRA approved individual.
- It is the responsibility of the PI to ensure that persons no longer needing access to areas where select agent or toxins are used or stored are removed from Tulane University's registration. PI's must notify the Office of Biosafety in writing.