Ongoing suitability assessments are performed in direct response to a regulatory requirement to determine an individual’s suitability for access to Tier 1 BSAT and to ensure that the individual continues to merit access. The ongoing assessment process shall be performed on an annual basis for all employees enrolled in the BSAT program. All individuals with access to the Tier 1 BSAT are subject to the ongoing suitability assessment program although for employees new to the program, it is not necessary to assess their suitability more than once per calendar year. Therefore an employee who has undergone a pre-access suitability assessment will not be required to undergo an ongoing assessment within the same year, but shall be assessed on an annual basis. It is at the discretion of the Review Panel to assess individuals under special circumstances which may require more than one assessment in a single calendar year. There are a series of required elements within the ongoing assessment program which include the following:

A mechanism shall be in place to allow and support self and peer-reporting of any and all behaviors of concern or questionable in nature. The program is concerned with incidents or actions that could affect an individual’s ability or eligibility to work with/ or have access to Tier 1
BSAT, and safeguard those materials from loss, theft or release. Anonymous reporting shall be available to protect peers from reprisal.

Ongoing monitoring of suitability shall be performed for all individuals with access to Tier 1
BSAT.

All ongoing candidates shall have annual training on entity policies and procedures for the following areas: o Reporting o Evaluations o Corrective Actions
A brief overview of these procedures is outlined in the Security Plan for Tier 1 BSAT. In addition, you may contact Environmental Health and Safety for a copy of the Suitability Assessment Program.
As mentioned in the Suitability Program and Pre-Access Suitability Plan, there are mechanisms in place to allow for self and peer reporting to accommodate the reporting of concerning incidents or conditions that could affect and individual’s ability to have access to or work safely with Tier 1 BSAT, or safeguard such agents against theft, loss or release. In an effort to protect reporting parties from reprisal, anonymous means are also in place.
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Such behaviors or incidents that merit reporting may include the following. Additional actions or behaviors may also merit action of their own if you feel that safety could be at risk. It is better to ask if you are unsure than to stay silent and wonder. Reported events are investigated for merit before any action is taken. Here are some examples of circumstances that should be reported.
1.
Circumstances that may affect SRA status of an individual;
2.
Circumstances that may affect the ability of an individual to perform his or her job in a safe and secure manner; a.
Distracted b.
Increased number of mistakes c.
Increased number of risky behavior
3.
Significant changes in behavior, attitudes, mood, demeanor or actions; a.
Increasingly withdrawn b.
Significant and prolonged deterioration in appearance c.
Unjustified anger or aggression d.
Unexplained absences e.
Signs of alcohol/drug abuse f.
Criminal activity
4.
Stated or implied threats to colleagues, institutions, BSAT security, laboratory animal’s well being or general public;
5.
Willful non-compliance with select agent regulations;
6.
Any information that causes an individual to have concerns about his or her own ability to perform a job safely and securely;
7.
Any circumstances that appear suspicious: a.
Lab work not corresponding to official project or goals b.
Request for security or lab information without justification c.
Acts of vandalism or property damage d.
Attempts to gain unauthorized access for friends or colleagues
8.
Unlawfully carrying weapons (or carrying weapons in violation of institutional rules);
9.
Providing false information on applications or other formal institutional documents; and
10.
Unauthorized work performed by and individual(s) in a facility during off-hours.
All persons with access to Tier 1 BSAT have the duty to report any suspicious or concerning behavior involving self, peer, strangers or otherwise. Examples of actions or behaviors that may warrant a report are listed above in the section titled “Reportable Conditions or Behaviors.” Failure to report suspicious or concerning activity may open the lab to vulnerabilities and could be cause for disciplinary action for failing to act or address security concerns. To protect those who may report a coworker or peer, anonymous reporting methods are available. A reporting form can be downloaded from the EH&S website and sent to EH&S attn: BSAT Information and marked as “Confidential”. A similar method can be through sending an e-mail to ehs@cpp.edu
stating the behavior of concern and making mention to the
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desire to remain anonymous. A final method can utilize the contact form located on the EH&S website to report concerns. All reports are taken seriously and are verified before any action is taken. The result of a report may trigger a spontaneous inspection “check-up” which is done at any time regardless of complaints. If necessary, the lab personnel may be scheduled for interviews with the assessment panel to screen for concerns. If the reported concern is verified, the individual will be given the opportunity to respond to any allegations regarding safety or security concerns, security procedures will be discussed and the panel will decide whether to continue the individual’s access to Tier 1 BSAT or to rescind access.
A documentation of the incident will be placed in the individual’s annual performance evaluation for future reference. Depending on the nature of the incident and the severity, if access is continued, it may be contingent on an additional assessment within the same calendar year.
Opt-Out:
All personnel with approved access to Tier 1 BSAT are granted the right to terminate their access to Tier
1 BSAT on a voluntary basis, referred to as an “Opt-Out”. An opt-out has no penalty and can be for an extended period of time. Situations that may merit an opt-out may be paternity/maternity leave, bereavement leave, sick leave, sabbatical, extended medical leave etc. To opt-out, the individual must consult with EH&S to discuss the terms and duration of their absence, if an interim position will be appointed or required etc.
Self/ Peer Reporting:
Self reporting is a process that can be used to re-evaluate your own fitness and suitability to work with
Tier 1 BSAT. This process would be used if one had reason or cause for concern relating to one’s abilities in the lab. Examples of this may be deteriorating medical conditions, life changing events, unusual or overwhelming stress in one’s personal life etc. Even as individuals with access to Tier 1 BSAT, to preserve the safety, integrity and security of regulated material, we have the duty to report such concerns.
Peer reporting follows the similar process in that as approved Tier 1 BSAT workers, there is a duty to act and question behavior that is questionable or cause for concern. Like the situation above, there are reporting methods available but due to the nature of peer reporting, anonymous methods can be used to protect the reporting party from any fear of reprisal for reporting such incidents. In either case, all reported cases will be evaluated and reviewed by the assessment panel. If there is cause to terminate or rescind Tier 1 BSAT access, it may be done so in one of two ways. The individual may opt to voluntarily withdraw from the program (de-enroll) in lieu of the outcome of the investigation. The second process would require the panel to recommend to the RO that access be terminated on a temporary or permanent basis. Should temporary withdrawal be the chosen mode of action, documentation is placed in the annual performance evaluation to that effect, indicating the duration of time required before the individual may be reinstated. Permanent removal will be done when necessary and cannot be withdrawn. The individual’s annual performance evaluation will outline the questionable or concerning actions and the file will be closed. Individuals with a temporary termination may be granted access to
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Tier 1 BSAT upon another pre-access suitability assessment, all required training and contingent on panel approval. The reinstated individual will be in a probationary status for 1 year at which time their performance will be re-evaluated before finalizing their re-admittance to the program. All forms of termination except in the event of a voluntary opt-out (non-disciplinary action) shall be reported to the
Federal Select Agent Program.
As described in the Tier 1 Select Agent Suitability Program, all records shall be maintained within Human
Resources due to the nature of the confidential material. All panel meetings will be held within Human
Resources and any documents pertaining to the confidentiality of the meetings or interviews, including but not limited to, assessment questionnaires, annual performance evaluations, written complaint reports, panel findings and records regarding disciplinary action shall remain within the Human
Resources department and Environmental Health and Safety.
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