Developmental Milestones/Developments to Date:
Current Assessment/State of the Field:
See special feature on Personnel Reliability in the Biosecurity Commons Review, May 2010
Inwald, Robin, E., Brockwell, Albert, L., “Predicting the Performance of Government Security Personnel with the IPI and MMPI,” Journal of Personality Assessment, 56 (3), 522-535, 1991.
- “Because past behavior has consistently been shown to be the best predictor of future behavior, the relative accuracy of the IPI prediction equations is not surprising.” p. 532
Sackett, Paul R. and Wanek, James E., “New Developments In The Use Of Measures Of Honesty, Integrity, Conscientiousness, Dependability, Trustworthiness, And Reliability For Personnel Selection“, Industrial Relations Center, University of Minnesota, 1996
- Two Categories of Integrity Tests: Overt Integrity Tests- The overt integrity tests consists of two sections. The first measures the individual’s attitudes towards theft, and asks the individual about how often he/she believes theft occurs, how easy it is to commit, punitiveness toward theft, if they believe theft can be justified, and questions to determine the individual’s own honesty. The second section directly asks about the individual’s own history with theft and other wrongdoing.
- Personality-Oriented Measures- This type of instrument aims to determine the individual’s level of dependability, conscientiousness, social conformity, thrill-seeking behavior, trouble with authority, and hostility.
- Possible Negative Effects of Integrity Tests: In a 1983 report, the Office of Technology Assessment says, “First, the reputational effects of the label “dishonest” are asserted to be greater than labels attached due to other tests. Second, if integrity tests become widespread, individuals mistakenly labeled dishonest could be permanently barred from the workforce. Third, labeling may create a self-fulfilling prophecy: if organizations already view an individual as dishonest, the individual may conclude that there are no longer sufficient incentives to refrain from dishonest behavior.(p.791-792)”
Snyder, James, “Role of the Hospital-Based Microbiology Laboratory in Preparation for and Response to a Bioterrorism Event,” Journal of Clinical Microbiology. pg. 1-4, Vol. 41, No.1. Jan. 2003
- “The main role of the hospital-based clinical microbiology laboratory in support of a biothreat, biocrime, or act of bioterrorism is to “raise suspicion” when a targeted agent is suspected in a human specimen.”(Pg. 1)
- “These plans include the following: (i) criteria for distinguishing the type of bioterroism event; (ii) information regarding access to and utilization of the LRN, including diagnostic testing protocols; (iii) safety guidelines; (iv) communication and notification protocols…” (Pg. 1)
- “Therefore, risk assessment becomes the responsibility of the clinical microbiologist, infection control personnel, hospital risk management office, and infectious disease physicians.” (Pg. 3)
- “The laboratory, preferably the laboratory director, must establish and include in the laboratory bioterrorism response plan a notification policy that is enacted when a suspicious isolate cannot be ruled out and must be referred to the next higher level laboratory for confirmation of the organism’s identity.” (Pg. 3)
Bush, George, W., “Homeland Security Presidential Directive-12,” August 27, 2004
- “Wide variations in the quality and security of forms of identification used to gain access to secure Federal and other facilities where there is potential for terrorist attacks need to be eliminated. Therefore, it is the policy of the United States to enhance security, increase Government efficiency, reduce identity fraud, and protect personal privacy by establishing a mandatory, Government-wide standard for secure and reliable forms of identification issued by the Federal Government to its employees and contractors.”
- “In order to do so, the President suggests that the Secretary of Commerce to establish a Federal standard for secure and reliable forms of identification. After the establishment of such a standard, the President calls for the heads of executive departments and agencies to create a program to ensure that identification issued by their departments and agencies meet the standard. The heads of executive departments and agencies, ‘shall require the use of identification by Federal employees and contractors that meets the Standard in gaining physical access to Federally controlled facilities and logical access to Federally controlled information systems.'”
Editors, “Steps for Preventing the Misuse of Biological Research“, Genetic Engineering and Biotechnology News, January 15, 2006 http://www.genengnews.com/articles/chitem.aspx?aid=1219&chid=0
- “In addition to the biosafety and biosecurity regulations currently in place to oversee biological research, it is now argued that measures are also needed to prevent the techniques developed and knowledge generated from being misused.”
- “The American Society for Microbiology (ASM) added concerns about the misuse of biological research to its code of ethics in April 2005. ASM members are now obligated to discourage any use of microbiology contrary to the welfare of humankind, including the use of microbes as biological weapons and will call to the attention of the public or the appropriate authorities misuses of microbiology or of information derived from microbiology.”
Editors, “The National Industrial Security Program report.” United States, Information Security Oversight Office. February 28, 2006. Last Accessed April 17, 2016 from http://babel.hathitrust.org/cgi/pt?id=pur1.32754073515078;view=1up;seq=5
- “This report provides information on the current status of the National Industrial Security Program (NISP) as part of the Information Security Oversight Office’s (ISOO’s) responsibilities to implement and monitor the program under Section 102(b) of Executive Order 12829, as amended, “National Industrial Security Program.”
- “This is part of our continuing evaluation of Government and Industry’s efforts to achieve the goal of establishing an integrated and cohesive program that safeguards classified information while preserving the Nation’s economic and technological interests”
Editors, “National Industrial Security Program Directive No. 1 ACTION Final rule” Federal Register. 6 pages. April 8, 2006.
- “The Information Security Oversight Office (ISOO), National Archives and Records Administration (NARA), is publishing this Directive pursuant to section 102(b)(1) of Executive Order 12829, as amended, relating to the National Industrial Security Program.”
- “This order establishes a National Industrial Security Program (NISP) to safeguard Federal Government classified information that is released to contractors, licensees, and grantees of the United States Government.”
- “Redundant, overlapping, or unnecessary requirements impede those interests. Therefore, the NISP serves as the single, integrated, cohesive industrial security program to protect classified information and to preserve our Nation’s economic and technological interests.”
- “This Directive sets forth guidance to agencies to set uniform standards throughout the NISP that promote these objectives.”
- “The NISPOM applies to release of classified information during all phases of the contracting process.”
United States Department Of Defense, “Instruction Number 5210.89- Minimum Security Standards for Safeguarding Biological Select Agents and Toxins“, April 18, 2006 http://www.fas.org/irp/doddir/dod/i5210_89.pdf
- E3.1.4. A current and favorable personnel security investigation is required for all personnel whose duties require access to Biological Restricted Areas and BSAT. Personnel security investigations will be comprised of the following:
- E18.104.22.168. A National Agency Check with Local Agency Checks and Credit Checks (NACLC) for military and contractor employees.
- E22.214.171.124. An Access National Agency Check with Credit Checks and Written Inquiries (ANACI) for civilian employees.
- E126.96.36.199. A favorably adjudicated security clearance at the SECRET or higher level suffices for the personnel security investigation.
- E3.2.1. Individuals identified by the Certifying Official as having a legitimate need to access BSAT and Biological Restricted Areas shall be screened for suitability and reliability. They shall be emotionally and mentally stable and trustworthy, physically competent, and adequately trained to perform the assigned duties. They shall complete a current and favorable personnel security investigation adjudicated to national security standards, with periodic reinvestigations according to Reference (h) and described in paragraph E3.1.4. Personnel will pass a urinalysis test for illegal drug/substance use before certification for access to BSAT. They will also be subject to random urinalysis tests.
United States Department Of Defense, Biological Personnel Reliability Program (BPRP), 2006 http://www.fas.org/irp/doddir/dod/i5210_89.pdf
- “The purpose of the BPRP is to ensure that each individual who is authorized access to BSAT, and to escort and/or supervise personnel with access to Biological Restricted Areas and BSAT, including Responsible and Certifying Officials, meets the highest standards of integrity, trust, and personal reliability. Determination of integrity and reliability shall be accomplished, in part, through the initial and continuing evaluation of individuals assigned duties associated with BSAT. The continuing evaluations will ensure these individuals do not pose a risk to the public health and safety, or national security.”
- E4.2.2. The Certifying Official shall certify the eligibility of an individual for access to BSAT based on factors including a favorable personnel security investigation, an evaluation of the individual’s physical and mental capability, appropriate personnel and medical records, and a personal interview. The eligible individual will sign an agreement affirming his or her responsibility to abide by the requirements for maintaining BPRP certification.Qualifying Standards:
- E188.8.131.52. Emotionally and mentally stable, trustworthy, physically competent, and adequately trained to perform the assigned duties.
- E184.108.40.206. Dependability in accepting and executing BPRP responsibilities.
- E220.127.116.11. Flexibility and adaptability in adjusting to a restrictive and demanding work environment with BSAT that must be strictly controlled and secured.
- individuals are also subject to a Personnel Security Investigation, medical evaluation, personal interview, drug/substance abuse testing
Lindorff, Dave, “NASA Scientists Challenge Security Rules“, The Nation, August 30, 2007 http://www.thenation.com/doc/20070910/lindorff
- “Scientists at NASA’s Jet Propulsion Laboratory and Goddard Space Flight Center are up in arms over a new requirement by NASA that they submit to detailed FBI scrutiny of their backgrounds in order to obtain clearance to go to work. They are claiming that the agency may be trying to control or silence them about issues like global warming.”
- “While the security crackdown at NASA is technically in compliance with Homeland Security Presidential Directive No. 12, that directive is actually fairly flexible, requiring each agency to establish the identity of each employee but leaving it up to each one to decide how to do it. Significantly, even the Department of Energy, at its Los Alamos facility, where much work is top-secret, has not resorted to the kind of blanket investigations NASA has ordered for JPL and Goddard.”
- “Interestingly too, the background checks are only required of permanent employees. People who come to work at JPL or Goddard for less than six months don’t need them–a curious lapse if the concern is security.”
Hafer, Nathaniel et al., “How Scientists View Law Enforcement” Science Progress, February 2009
- “Ancedotal evidence, including several high-profile cases of scientists under criminal investigation, has led to the impression that many in the scientific community hold a negative view of law enforcement.”
- “…scientists holding high or medium security clearances- and therefore arguably more likely to have firsthand contact with federal agents- had the highest level of warm views and the lowest level of cool views toward the FBI of any cohort covered in the survey.”
- On the reasons for negative attitudes towards law enforcement: “Specific concerns include the belief that law enforcement does not understand their work, the belief that law enforcement is more interested in restricting research for security purposes than they are in the scientific value of the work, that law enforcement has an overzealous approach to security issues and an interest in censorship, and the fear that law enforcement will restrict the publication of some research.”
- However, the survey revealed that scientists are generally concerned that they would be asked to monitor the activities of a colleague, which 67 percent felt is not a legitimate reason to be contacted by the FBI.”
- “Nonetheless, the low percentage of scientists with previous law enforcement contact suggests that many of the attitudes of distrust are based upon stereotypes rather than actual experiences and that these perceptions have led to an elevated level of suspiciousness that law enforcement will have to overcome in the future.”
- “Increasing scientific literacy among law enforcement personnel who work with scientists may be one important avenue to ensure a strong relationship and clear communication between the law enforcement and science communities.”
Rodi, Diane J., “Executive Order Working Group on Strengthening the Biosecurity of the United States” May 2009 http://orise.orau.gov/emi/annual-meeting/2009/presentations/SCAPA_Rodi.pdf
- A comprehensive PRP requires:
- background check
- polygraph exam
- initial and random drug/alcohol tests
- mental health evaulation by psychiatrist and medical records examination by CMA
- monitoring by supervisors
- peer reporting
- periodic re-evaluations
- Results of the NSABB meeting on April 29, 2009:
- “Yes to enhanced personnel relibaility measures but no to formal national PRP.”
- “Yes to strengthening the current SRA process.”
- “Yes to enhancing the culture of responsibility and accountability via education and outreach.”
- “List of BSATs should be reduced or stratified.”
Sawyer, Kathy, “AAAS Report Warns that New Lab Security Measures Could Undercut Biological Research“, American Association for the Advancement of Science, May 29, 2009 http://www.aaas.org/news/releases/2009/0529high_containment_labs.shtml
- “A review of existing biosafety training programs, conducted by two units of AAAS, found that the programs “may already address concerns” that have arisen in Congress and the executive branch about the reliability of personnel at the laboratories, known as high-containment facilities. The report recommends that, before instituting new requirements, the government should “consider existing employment and biosafety training practices…as they may already contribute to vetting of personnel” and the prevention of “malicious actors or unstable personnel” from gaining access to hazardous pathogens.”
- “The report raises questions about the proposed use in biological research of the kind of “personnel reliability programs” long used in nuclear and chemical weapons laboratories and which may include psychological screening, drug and alcohol abuse testing, background investigations, polygraph testing, credit checks, and top-secret clearances.”
- Mark Frankel, director of the AAAS Program on Scientific Freedom, Responsibility and Law says, “Clearly one of the main things we wanted to do is to draw attention to the issue of ‘personnel reliability’, which I do not think is well-recognized by life scientists out there in the field. They have absolutely no idea what’s coming.”
- “Biological research, by contrast, can present even greater challenges in that it deals mostly with live organisms that can be grown from a small sample into large numbers. Most are pathogens that occur in nature and can be isolated from soils or infected hosts outside the lab and used to cause harm. But there is little evidence that traditional nuclear-style security measures added inside the laboratories would mitigate such dangers, the scientists argue.”
- “Since 2001, the number of laboratories designed to handle dangerous biological agents has soared from a handful to some 336 entities spread among the government sector, universities, independent research institutes and private industry. This happened mainly because terrorist attacks and the emergence of new infectious diseases led the government to channel money into biodefense and related public health activities. The number of researchers and support staff registered to work with potentially harmful microbes now totals more than 14,600.”
National Science Advisory Board For Biosecurity, “Enhancing Personnel Reliability among Individuals with Access to Select Agents” May 2009. http://oba.od.nih.gov/biosecurity/meetings/200905T/NSABB%20Final%20Report%20on%20PR%205-29-09.pdf
- ”Recommendation” 1: “It is appropriate to enhance personnel reliability measures for individuals with access to select agents, but the promulgation of a formal, national Personnel Reliability Program is unnecessary at this time.”
- ”Recommendation” 2: “Incorporate into the SRA [Security Risk Assessment] process the periodic cross-checking of individuals with favorable SRAs against federal databases. …Expand the SRA prohibition regarding terrorism. …Strengthen screening of foreign individuals. …Clarify the reference to “mental defective” on the SRA form.
- ”Recommendation” 3: “The culture of responsibility and accountability should be enhanced at institutions that conduct select agent research.”
- ”Recommendation” 4: “Professional societies should continue to encourage an ongoing dialogue about personnel reliability to maintain vigilance about biosecurity issues throughout the research community and to foster community-based solutions.”
- ”Recommendation” 5: “The List of Select Agents and Toxins33 should be reduced or stratified.”
- “Personnel reliability measures aim to ensure that individuals granted access to sensitive materials are trustworthy, responsible, and stable, and can competently perform their duties. (p.4)”
- “Certain research facilities (notably federal) have instituted formal Personnel Reliability Programs to provide additional measures to help ensure that individuals with access to select agents meet additional standards of reliability. Current PRPs are modeled after those within the traditional surety programs and may include extensive background investigations with interviews of character references, security clearances, medical evaluations that may include a review of complete medical records, psychological testing, drug and alcohol testing, polygraph examinations, credit checks, and a comprehensive review of service and employment records. PRPs usually also involve formal mechanisms for ongoing monitoring that can include requirements for self-reporting, peer-reporting, ongoing monitoring by supervisors, and penalties for noncompliance. (p.5)”
- “The potential benefits of enhanced personnel reliability measures must be carefully weighed against the more likely negative consequences that such measures could have on the research community…The promulgation of additional reliability measures could serve as a powerful disincentive to those who wish to and would responsibly conduct research on select agents because the most talented young researchers, those with many options for research paths, may be far more likely to enter fields with less onerous regulatory requirements. Thus, a burdensome national personnel reliability program may not only drive scientists from important select agent research, but also drive select agent research out of academia and potentially out of the U.S. into countries with less stringent regulations. (p.6)”
- “Paradoxically, measures aimed at enhancing the biosecurity of select agent research could have the unintended consequence of actually decreasing national security if such measures diminished the capacity for the U.S. to prepare for, and respond to, emerging threats by diminishing the U.S.’ ability to recruit top scientists and develop vaccines, treatments, and other countermeasures. Furthermore, the institution of reliability measures could isolate select agent researchers from the mainstream scientific community, and such isolation might increase the risk of the insider threat. (p.6)”
- “Under the current Select Agent Rules implemented by the U.S. Department of Health and Human Services and USDA/APHIS, an individual requiring unescorted access to select agents as a part of his or her job must have a Security Risk Assessment by which his or her potential status as a restricted or prohibited person is evaluated…An individual must provide fingerprints and disclose aspects of possible criminal history, use of illicit drugs, mental-health history, and whether dishonorably discharged from the U.S. Armed Services…Federal databases are then utilized to examine an individual’s possible criminal background, potential terrorist ties, and immigration status. (p.3)”
Greenberger, Michael, “Strengthening Security and Oversight at Biological Research Laboratories” September 22, 2009 http://judiciary.senate.gov/pdf/09-09-22%20Greenberger%20testimony.pdf
- “Since 2001, funding for biodefense research has substantially increased. In 2001 the National Institutes of Health Biodefense Research Funding totaled $25 million, but by 2005 had increased to $1.7 billion. (p.3)”
- “The National Science Advisory Board on Biosecurity, the Commission on the Prevention of W/md Proliferation and Terrorism, and the Government Accountability Office were independently charged with investigating different aspects of biosecurity at biosafety laboratories. (p.3)”
- “Security Risk Assessments are mandated by the PHBPA, for every individual who seeks to work with Select Agents. Using the criteria from the PATRIOT Act, the SRA is intended to preempt “Restricted Persons” from gaining access to these potentially harmful bioagents…The SRA most notably involves comparing an applicants fingerprints against criminal and terrorist databases and must be renewed every 5 years. (p.10)”
- “The CDC notified the NSABB that recently the FBI has begun to bi-annually cross-check approved individuals against specified databases to verify that the individuals have not slid into a restricted category…However, the FBIs interim crosscheck is not presently required by law or regulation. (p.11)”
- PRPs are more commonly used in military research laboratories, and are more extensive than the SRA. *”A culture of strict security has always been the norm in these (military) facilities and so the PRP are not seen as a hindrance to the recruitment and retention of talented scientists. (p.11)”
- “Apart from the Select Agent regulations, there is no current federal requirement for the development of a biosecurity program, as distinct from a biosafety program at any of the BSL-1 through BSL-4 laboratories. The Select Agent regulations require that a biosecurity plan exist, but they do not establish the specific components of the plan. (p.13)”
- Recommendation: “The PHBPA and the ABPA grant oversight for select agents to the HHS and USDA respectively. Additionally agents, which overlap the human, animal, and plant categories because of their potential to impact each species, can be registered with either agency. Recombinant DNA research is additionally covered by NIH guidelines. Depending on the nature of the action, multiple other agencies and regulations may also be involved. (p.24)”
- Recommendation: “Incidents should be reported promptly to one centralized agency for BSL-3 and 4 laboratories. Reports should be regularly reviewed on a timely basis. The review should not be punitive in nature and should be geared towards improving security and safety across labs. The review should be expeditiously shared with all BSL-3 and 4 institutions, so that investigators working with these agents can learn from each other and share solutions in an organized manner. (p.25)”
- Recommendation: “Each laboratory is subject to inspection and site visits to assess compliance with the Select Agent regulations. (p.26)”
- Recommendation: “Improve the SRA to achieve more stringent screening while not imposing the onerous process of a formal PRP. (p.26)”
- Recommendation: “The informal practice of checking the names of individuals with favorable SRAs against the Counterterrorism Watchlist and other databases by the FBI that is now occurring about every six months should be formally incorporated into the SRA process. (p.27)”
- Recommendation: “The NSABB also identified optimal personnel characteristics that should be considered for candidates for employment in high containment labs. Research on the reliability and practicality of assessing for these characteristics should be undertaken and the accreditation process should be adapted to the results of that research. (p.27)”
- Recommendation: “Military institutions have fully developed security models in place that are not practical for the private sector. A non-military model is needed for BSL-3 and 4 biosecurity. An ideal model of this sort would take into account the need for integrating biosecurity measures with the open educational nature of university campuses. (p.27)”
Committee on Laboratory Security and Personnel Reliability Assurance Systems for Laboratories Conducting Research on Biological Select Agents and Toxins, National Research Council of The National Academies, Report Released September 30, 2009. http://www.nap.edu/catalog.php?record_id=12774
- “The Committee was asked to consider the appropriate framework of laboratory security and personnel reliability measures that will optimize benefits, minimize risk, and facilitate the productivity of research.”
- ”Recommendation” 1: “…personnel with access to select agents and toxins should receive training in scientific ethics and dual-use research.”
- ”Recommendation” 2: “… a Biological Select Agents and Toxins Advisory Committee (BSATAC) should be established. … [to]… Promulgate guidance of the Select Agent Program; … Promote harmonization of regulatory policies and practices.”
- ”Recommendation” 3: “The list of select agents and toxins should be stratified in risk groups according to the potential use of the agent as a biothreat agent, …mechanisms for the timely inclusion or removal of an agent or toxin from the list are necessary and should be developed.”
- ”Recommendation” 4: “Because biological agents have an ability to replicate, accountability is best achieved by controlling access to archived stocks and working materials. …[as opposed to] counting the number of vials.”
- ”Recommendation” 5: The appeals process for Security Risk Assessments should be broadened beyond mere checks for factual errors.
- ”Recommendation” 6: “… define minimum cross-agency physical security needs.”
- ”Recommendation” 7: Dedicated funding should support an independent evaluation of the Select agent Program to assess benefits and consequences of the program.
- ”Recommendation” 8: “Inspectors of select agent laboratories should have scientific and laboratory knowledge and experience, as well as appropriate training in conducting inspections specific to BSAT research. Inspector training and practice should be harmonized across federal, state, local, and other agencies.”
- ”Recommendation” 9: A separate category of support should be allocated for BSAT research due to the costs of security.
Ippolito, Giuseppe, et al “European Perspective of 2-Person Rule for Biosafety Level 4 Laboratories,” Emerging Infectious Diseases, P. 1858, Vol. 15, No. 11, November 2009.
- ”Recently, the directors of Biosafety Level 4 (BSL-4) laboratories in the United States published their views of the requirement of having ≥2 persons present at all times while biological work is undertaken in a BSL-4 laboratory.”
- ”we support the authors’ initiative and broadly agree with their position. The consensus among European BSL-4 experts is that, in the interest of safety, standard practice should be for all laboratories to perform a risk assessment before any activity is undertaken.”
- ”They concluded that safety and security would be better assured in some situations by video monitoring systems rather than by the presence of a fellow scientist.”
- ”A 2-person rule is inappropriate simply because the best approach is not to have inflexible rules that are not objectively assessed according to laboratory-specific circumstances.”
- ”Surveillance video monitoring and data storing have their place in protecting laboratory facilities from unauthorized access and theft of materials, but their effectiveness for ensuring proper handling of pathogens is quite limited.”
Committee on Laboratory Security and Personnel Reliability Assurance Systems for Laboratories Conducting Research on Biological Select Agents and Toxins, “Responsible Research With Biological Select Agents and Toxins” National Research Council of the National Academies, 2009
- Issues in Personnel Reliability:
- “Efforts at screening for rare individuals or behaviors will therefore inevitably struggle with concerns about either failing to identify someone who has the disqualifying background or behavior or identifying someone as having disqualifying background or behavior when s/he does not.”
- “Experts in personnel screening have long been concerned with the challenge that a system applicants find too intrusive or unfair could make even successful applicants feel the selection process is unjust, creating negative feelings or attitudes that could ironically contribute to someone’s becoming disgruntled and potentially susceptible to the very behavior screening is intended to prevent.”
- Issues with Current SRA [Security Risk Assessment]:
- “The very small number of rejections and appeals reported by the CDC-158 rejections out of a total of 28,593 applications processed and 51 appeals, of which 21 resulted in the denial being overturned-can be interpreted either that the screening is not restrictive enough, allowing potential risks to gain access to BSAT, or as effective institutional pre-employment screening that weeds out those ineligible for access to BSAT prior to the SRA process.”
- “There is a substantial lack of understanding of how issues related to sexual orientation and mental health are addressed by the SRA.”
- Potential Changes to the Current SRA:
- Adding Additional Databases to the Current Screening
- Adding a Mandatory Drug Test- The SRA only assesses current drug use through a question on the application form, so the issue is whether to add a mandatory test to verify an applicant’s statement that he or she is not using illegal drugs.
- Adding a Credit Check or Financial History- A major reason for considering addition of financial information is that greed or susceptibility to bribery has been found to be a factor, in some cases, in the decision to become an accomplice to those undertaking illegal acts.
- Adding an Adjudication Process- The current SRA system has no statute of limitations on disqualification: it does not matter how long ago the offense was committed. There is also no consideration of extenuating circumstances.
- Identifying Potential Insider Threats Through Testing:
- “Polygraphs used for investigations of a particular occurrence are quite focused, concentrating on one event, and retrospective, so that precise true/false questions of fact are the focus of the exam. The study found that polygraphs were far less reliable for other purposes; for example, in national security screening, the exam covers a range of past behaviors, which might include ambiguous or speculative situation where the examiner and the subject do not have the same picture of a situation…”
- “One of the most widely used clinical personality assessments is the Minnesota Multiphasic Personality Inventory. It is used in nonclinical settings to identify a range of psychopathologies and to assess persons who are candidates for high-risk public safety positions…”
- “There is little evidence that potential bioterrorists are more likely to come from among the ranks of those with a given specific psychopathology than those motivated by some other reason, such as commitment to a cause that uses terrorism or those who would undertake terror for financial gain.”
Editors, “Report of the Working Group on Strengthening the Biosecurity of the United States”, 2009 http://www.hhs.gov/aspr/omsph/biosecurity/biosecurity-report.pdf
- Key Finding: “Improvements can be made in the current Select Agent Program regarding the screening of individuals both prior to granting access to BSAT and after access has been granted.”
- Key Recommendation: “Enhance the Security Risk Assessment at the Federal level to allow for improved vetting of the U.S. citizens and foreign nationals. Require continuous monitoring measures (supervisor accountability, self- and peer-reporting) at the local level and evaluate the feasibility of reporting of derogatory information to improve management oversight of individuals with BSAT access. (p.37)”
- Areas of Improvement to Personnel Security
- Granting Initial BSAT Access- Security Risk Assessments and Initial Access
- “The Security Risk Assessment is generally limited to U.S. government databases and therefore, information such as foreign criminal history records may not be accessible. As a result, FNs may receive less scrutiny during the Security Risk Assessment process than U.S. citizens.”
- “Background checks performed by a U.S. Consulate as part of the visa granting process do not capture all FNs who will apply for BSAT access and if performed, may not be current.”
- Queries sometimes provide inaccurate information because of inconsistent reporting and processing of information. (p.45)
- The USA Patriot Act restricts people with mental disabilities or who have been sent to a mental institution from access to BSAT. The Working Group suggests that previous commitment to a mental institution should not keep someone from having access to BSAT if the individual is functional and the cause for treamtment has been resolved. (p.46)
- Suitability for Initial BSAT Access
- “There are no nationally established criteria in the Security Risk Assessment beyond the restricted and potential prohibitive categories to determine an individual’s suitability to access BSAT.”
- “…there is no other requirement (such as drug testing) to determine if an individual falls into a restricted category as currently being an unlawful user of a controlled substance when they apply for BSAT access.”
- “Aspects of an individual’s health may be relevant to their suitbaility to access BSAT, but screenings to address these aspects are not addressed in the SRA. (p.47)”
- Continual Monitoring of Personnel
- With the SRA only being administered every five years, it is possible for an individual to fall into one of the prohibited or restricted categories and not be recognized until their next assessment.
- “…(the current SRA) does not address any type of continuous evaluation of employed personnel, to include local institution initial and periodic interviews, self- and peer reporting, or the reporting of circumstances that would affect or diminish an individual’s ability or reliability to perform duties related to BSAT.”
- “There is no requirement for continual physical or mental health monitoring of individuals once BSAT access is granted. (p.48)”
- Recommendations for Enhancing Personnel Security”
- “Establish a working group, including Federal and non-Federal subject matter experts from the scientific, intelligence, security, human resources and healthcare communities, that will investigate and establish guidance and training on suitability criteria, above and beyond restricted and potential prohibited categories…”
- “Assess the feasibility of the following recommendations: 1) An amendment to the SAR requiring that ROs report the details of derogatory information leading to permanent termination of BSAT access to CDC or APHIS for inclusion in a registry or repository. 2) A registry or repository containing derogatory information reported by the RO that can be used, in combination with results of the security risk assessment, for determining whether an individual should be granted BSAT access. (p.49)”
- “Screening: Identify a Federal agency that will 1)develop guidelines for vetting Foreign Nationals that require BSAT access and 2) will screen FNs according to these newly established criteria. The SAR should be amended such that this Federal agency, CJIS-BRAG, CDC, and APHIS collaborate to consider both the Security Risk Assessment results and the newly established criteria to grant or deny BSAT access.”
- “Visas: Require that the DoS provide a list of visa types that are appropriate for work with BSAT to the Select Agent Program. Require the Select Agent Program to disseminate this information to Responsible Officials. (p.50)”
- “Assess the feasibility of requiring drug testing (urinalysis) for intial BSAT access and determine whether such a testing program could be justified under a Fourth Amendment analysis. (p.50-51)”
- “Amend the SAR to require that a Security Risk Assessment be performed every three years for all individuals with access to BSAT.”
- “Assess the feasibility of random drug testing (urinalysis) for continued BSAT access to ensure that an individual does not fall into a restricted category.”
- “Ensure that all individuals who work with BSAT have access to an occupational health professional for referral of physical or mental health issues that arise after BSAT access is granted. (p.51)”
- Granting Initial BSAT Access- Security Risk Assessments and Initial Access