The Federal Security Advisory Panel (FESAP) Best Practices Checklist for Assessment of Current and Projected Needs for High or Maximum Containment Laboratory Space
S3: Science Safety Security
FESAP Function
In July 2010, Executive Order 13546 “Optimizing the Security of Biological Select Agents and Toxins (BSAT),” created and tasked the Federal Experts Security Advisory Panel (FESAP) to address policy issues relevant to the security of biological select agents and toxins.
The duties of the FESAP are solely advisory and shall extend only to the submission of advice or recommendations.
Background
In 2014, a series of incidents involving BSAT raised serious safety and security policy issues. The White House National Security Council (NSC) staff tasked the FESAP, in September 2014, to 1) identify needs and gaps and make recommendations to optimize biosafety, biosecurity, oversight, and inventory management and control for BSAT; 2) identify actions and any regulatory changes to improve biosafety and biosecurity; and 3) identify an approach to determine the appropriate number of high-containment U.S. laboratories required to possess, use, or transfer BSAT.
In response to these taskings, the FESAP delivered the December 2014 Report of the Federal Experts Security Advisory Panel. Among its other recommendations, Part IV of the report addresses the “Identification of an Approach to Determine the Appropriate Number of High-Containment U.S. Laboratories Required to Possess, Use, or Transfer BSAT”. The three-phase approach described in Part IV includes:
- Phase I: Federal Assessment
- Phase II: External Review Panel Assessment
- Phase III: USG Consideration of External Review Panel Assessment
An intended outcome of Phase I is a ‘best practices checklist’ to be used as a guideline by departments and agencies when considering the construction of high or maximum containment laboratories (HCL). The best practices checklist will help ensure that departments and agencies have considered the different potential options to address their containment research needs and could potentially enable a reduction in the time and cost for planning; design; the release of the request for funding; the award; and the construction of HCL.
The checklist should help departments and agencies in operationalizing generalized principles, foster the use of standard methodologies, and assist in developing templates that could be applied to guide assessments of current and projected needs for HCL space, as well as mechanisms to efficiently meet those needs.
Scope
This Best Practices Checklist is advisory in nature; it is intended to assist departments and agencies in determining and evaluating all possible options and variables when considering their HCL needs. This guidance is not exclusive and does not replace existing policy or regulations. Departments and agencies will still be required to abide by all applicable acquisition, procurement, and contracting regulations, policy, and guidelines.
This checklist is intended to be applied only to HCL supported by federal funding within the United States. For federally supported laboratories outside the United States, see the Department of State’s “Guiding Principles and Assessment Process Related to the Provision of Biocontainment Facilities to Foreign Countries.”
General Principles
Departments and agencies who are considering their current and projected needs for HCL space should adhere to the following general principles:
- Departments and agencies should be able to show a demonstrated need for HCL space, and should have a process that carefully considers alternatives before constructing new HCL space.
- Departments and agencies should demonstrate their commitment and ability to operate, maintain, and sustain the facility in a safe and secure manner upon completion.
- High or maximum containment laboratory space should be designed to conform to current U.S. biorisk management standards, as appropriate, and should be sufficient to meet mission requirements in a safe, secure, and efficient manner.
- Departments and agencies should ensure that a robust community engagement process is initiated before the construction of any new HCL buildings. Proactive community engagement is important for transparency, trust, and the ongoing operation of HCL facilities.
Best Practices Checklist: Factors for Consideration in Assessing High Containment Space Needs
The following checklist contains questions that departments and agencies should consider in operationalizing the general principles listed above. These questions may not have simple ‘yes’ or ‘no’ answers; departments and agencies should develop detailed responses for each.
This checklist is not intended to serve as a series of boxes that must be checked. Rather, it is intended to provide a comprehensive set of questions that department and agencies should consider throughout their planning process. It is intended as tool to help departments and agencies ensure that they are evaluating all possible options and variables when considering their HCL needs.