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4 Issues Related to Personnel Reliability
Pages 73-104

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From page 73...
... But because current practices and the prospect of additional measures related to personnel assurance have caused so much anxiety about the impact of the measures on the ability to attract and retain high-quality research and technical personnel and conduct the best science, the committee has devoted an entire chapter to these specific issues. The first part of this chapter discusses screening, that is, the process of identifying whether or not someone should be eligible to have access to BSAT materials.
From page 74...
... As discussed in this section, screening for security risks poses special issues. The current screening process for individuals to work in facilities conducting BSAT research is based on identifying any of a set of disqualifying behaviors/activities that would automatically and permanently deny a person access (see Chapter 2 for additional details)
From page 75...
... It is vital to acknowledge the formidable challenges posed by screening individuals for potential security concerns. The proportion of the population of job candidates who represent true security risks is unknown, but likely to be very small.
From page 76...
... the current SRA and whether changes to either the disqualifying background/activities or the operation of the process is warranted; and (2) whether other screening methods, in particular testing, would add to the confidence that one could identify problematic potential employees.
From page 77...
... . The very small number of rejections and appeals reported by the Select Agent Program -- 192 rejections out of a total of 31,349 appli cations processed and 58 appeals, of which 22 resulted in the denial being overturned3 -- can be interpreted either that the screening is not restrictive enough, allowing potential risks to gain access to BSAT facilities, or as effective institutional pre-employment screening that weeds out those ineligible for ac cess to BSAT materials prior to the SRA process.
From page 78...
... 5 The committee believes the Select Agent Program can help reduce these concerns by providing more specific guidance about what is meant by these terms and perhaps by including clarification on the SRA form itself.6 In making its assessments, the committee considered how the SRA com pares with other basic security and suitability screening carried out by the federal government. The broader context is important for understanding the committee's conclusions and recommendation; it seems reasonable, for example, to ask how the SRA compares to a process that enables 2.4 million people to have access to various levels of classified information (GAO 2009b)
From page 79...
... Discussion among the members of the committee, including several who have experience with the databases used for this type of screening, consultation with a number of outside experts, including in a public session during the committee's second meeting devoted to federal security and suitability screening practices, and public discussion about these issues sug gested that the SRA may be consulting even more databases than those in the routine federal security clearance process. Although there may be specialized databases held by other agencies to which the FBI would not have access, in formation available to the committee suggests that the databases used for the current SRA are equivalent or comparable to those used for most other federal screening processes.
From page 80...
... Adding a Credit Check or Financial History An obvious omission from the current SRA is querying an applicant's financial and credit history. At least some consideration of credit history is common in many sectors as part of pre-employment screening and standard practice in federal security clearance and suitability investigations.
From page 81...
... Judgment would inevitably be required, and the current SRA process does not include that kind of discretion. The committee concluded that the difficulties of establishing a meaningful baseline make adding credit or financial history to the current SRA screening process too challenging.
From page 82...
... RECOMMENDATION 5: The current Security Risk Assessment screen ing process should be maintained, but the appeal process should be expanded beyond the simple check for factual errors to include an oppor tunity to consider the circumstances surrounding otherwise disqualifying factors. Identifying Potential Insider Threats through Testing Introduction Policy discussions have included the issue of whether to require more extensive testing and evaluation of applicants to work with BSAT materials, perhaps as part of a formal Personnel Reliability Program.
From page 83...
... Psychological tests include both "normal range" testing and tests that measure possible aberrant or psychopathological traits. Polygraph Testing Polygraph testing is described here because it is used by some government agencies for national security screening -- including some who may conduct BSAT research.
From page 84...
... The subject's responses are then the basis for making inference to his or her future behavior. The polygraph study committee concluded that: Available evidence indicates that polygraph testing as currently used has ex tremely serious limitations in such screening applications, if the intent is both to identify security risks and protect valued employees.
From page 85...
... "Integrity tests" include a variety of instruments used to assess attitudes and experiences related to an individual's honesty, dependability, trustworthiness, reliability, and pro-social behavior. These are the tests most commonly used to identify potentially counterproductive workplace behavior.
From page 86...
... Personality Assessment Tools Concerns about insider threats also include those who are suffering from mental disorders severe enough to potentially cause them to commit illegal acts. In this section, we address the issue of whether such problems could be identified at the point of hiring; the challenge of identifying and responding to such problems once someone is already working in a facility is addressed later in the chapter.
From page 87...
... A key question is how well the many standardized tests developed to assess personality are able to identify potential problem employees. And even if the tests are effective for this purpose, one then needs to ask whether the traits they identify are related to the specific problem one is trying to solve: exclud ing potential insider threats and terrorists from the laboratory.
From page 88...
... But the process cannot be expected to address all disqualifying factors or, perhaps more importantly, all significant issues and personal changes that could occur in an individual's life during the five-year period of certification, including those that could potentially result in his or her becoming a security risk. The conclusion that one should not rely exclusively on screening to identify potential insider threats before hiring makes this recognition both important and troubling.
From page 89...
... RECOMMENDATION 1: Laboratory leadership and the Select Agent Program should encourage and support the implementation of programs and practices aimed at fostering a culture of trust and responsibility within BSAT entities. These programs and practices should be designed to mini mize potential security and safety risks by identifying and responding to potential personnel issues.
From page 90...
... The committee heard presentations about some types of processes in other sectors; Box 4-1 offers examples from the airline industry. The literature on insider threats further argues that an organization should have the necessary processes in place before the problem occurs (Turner and Gelles 2003)
From page 91...
... Flight Attendants Reporting: The flight attendants union also has a two-tier system. • The main source of assistance is via employee assistance programs (EAPs)
From page 92...
... , so an important task is to identify and supplement relevant existing case studies, commission new ones, and examine them all comparatively to highlight lessons relating to personnel reliability and security.15 As in evaluation efforts described in Chapter 5, these case studies will help move the policy discussions toward a better understanding of how to address the risk of the insider threat. The Challenge to Management As with screening, reducing the risk of an insider threat can be viewed as part of the larger set of challenges facing any manager.
From page 93...
... With this brief introduction, consideration is now given to research, evi dence, and experience that can inform development of systems to improve personnel reliability at institutions working with BSAT materials through fostering active monitoring and management. Fostering a Culture of Trust and Responsibility A goal in any organization where safety is a central challenge should be to foster a culture where individuals watch out for each other and take respon sibility for both their own performance and that of others.
From page 94...
... Moreover, the opportunity to develop and/or sharpen manage ment skills seems less likely to be seen as important for an academic scientific career than for a career in private or government environments. Education to Raise Awareness and Foster Responsibility Building a culture of trust and responsibility to reduce the risk that BSAT materials might be stolen for use by terrorists or used in acts of sabotage in the laboratory can draw upon longstanding traditions in the life sciences as well as more recent efforts focused on security risk.
From page 95...
... Dual use re search is a broader concept than BSAT, but it is reasonable to assume that much of the research conducted under the Select Agent Program could potentially be considered dual use. A series of NRC reports has endorsed education on dual use issues (NRC 2004ab, 2006, 2007b, 2009ab)
From page 96...
... . • Bioethics training, which largely reaches those in biomedical research including BSAT researchers, offers another potential venue, and, again, there are signs of interest from some in that community in taking on the additional issues (AAAS 2008)
From page 97...
... Current Training by Registered BSAT Entities The Select Agent Program requires all registered entities to provide training in biosafety and security before individuals can enter areas where select agents and toxins are handled or stored (7 CFR 331.15(a)
From page 98...
... . Management may also provide mechanisms for individuals to obtain help in dealing with concerns proactively via employee assistance programs (EAPs)
From page 99...
...  ISSUES RELATED TO PERSONNEL RELIABILITY Although not directed at the problem of preventing an insider threat of bioterrorism, the findings are informative for thinking about the design of sys tems for reporting and self-reporting. The research cited above concluded that: "There is no single policy that will make an organization seem trustworthy and no single procedure or practice that will guarantee that people will oercome all the barriers to coming forward.
From page 100...
... Summing Up Having occupational health specialists available and active in monitoring laboratory personnel could provide genuine assistance in monitoring for insider threats, at least for the type of behavior that is most likely to 18 This section does not address legal requirements that might be imposed by the Occupa tional Health and Safety Administration (OSHA)
From page 101...
... What happens to a person who "blows the whistle" on a colleague? Which disincentives, such as a fear of being sued, might keep managers from acting on warning signs, which in addition to any security risk, could undermine the integrity of the reporting system?
From page 102...
... The BSAT research community -- and the life sci ences community more broadly -- has a responsibility to help reduce the risk that the results of the knowledge, tools, and techniques developed for beneficial purposes are not misused. Given that no personnel screening process can be 20 "The attitudes of scientists toward law enforcement personnel are not vastly different from those of the general public....
From page 103...
... 0 ISSUES RELATED TO PERSONNEL RELIABILITY expected to predict the behavior of employees in all contexts at all times, active management, monitoring, and support for those working in BSAT laborato ries are key components of a comprehensive approach that builds trust and ultimately leads to safer and more secure BSAT research. Such programs are already in place in some of the laboratories carrying out BSAT research, but to be fully effective this type of program needs to be transformed into standard practice throughout the Select Agent Program.


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