Security Plan Guidance: Section 11(c)

Section 11(c)(1) of the select agent regulations requires the security plan to describe procedures for physical security, inventory control, and information systems control. These descriptions should reflect the policies implemented at the entity. This section explains different methods for ensuring that the entity’s security plan complies with the regulations.

Effective inventory control measures for select agents and toxins can deter and detect a variety of insider threats. How the inventory audits are conducted and inventory is maintained must be described in the entity’s security plan and inventory records must meet the requirements of section 17 of the select agent regulations. The security requirement includes:

• Current accounting of any animals or plants intentionally or accidentally exposed to a select agent.
• An accurate and current inventory for each select agent or toxin, including material in storage and working stock.
• Labeling and identifying select agents and toxins in the entity inventory in a way that leaves no question that the entity’s inventory is accurately reflected in the inventory records.
• Accounting for select agents and toxins from acquisition to destruction.
• See Inventory Audits for more detailed instructions on maintaining effective inventory control.