Guidance for Select Agent Regulation Training Requirements: Training Records
Section 15(d) states that the Responsible Official must ensure a record of the training provided to each individual with access to select agents and toxins and each escorted individual (e.g., visitors, etc.) is maintained. Section 17 (Records) requires that these records must be maintained for a period of at least three years. The record must contain:
- The name of the individual
- The date they receive training
- A description of the training provided
- The means used to verify that the employee understood the training
There are no specific requirements for how or in what format training records are to be maintained by entities. Electronic records are acceptable as long as that record includes all of the information required in Section 15 (Training) and is maintained in accordance with Section 17 (Records) of the regulations, and the RO is able to provide access to the electronic record upon request.
There must be a means for verifying that the employee understands the training they receive. There is no specific requirement for how the entity verifies that the individual understood the training. Entities may administer a test to determine if individuals understood the material or ask the individual to sign the record that they understood the training.
HHS Office of Inspector General and USDA Office of Inspector General Hotlines
The RO must document that information provided include the contact information of the HHSexternal icon Office ofexternal icon Inspector General Hotline external iconand the USDA Office of Inspector General Hotline external iconso individuals may anonymously report any safety or security concerns related to BSAT. Information should be provided for both HHS and USDA hotlines, regardless of whether the entity possesses HHS-only or USDA-only BSAT.