The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, submitted comments in response to the USDA’s Animal and Plant Health Inspection Service (APHIS) Notice of Proposed Rulemaking (NPRM) regarding the biennial review and republication of the Select Agent and Toxin List under the Agricultural Bioterrorism Protection Act of 2002. COGR expressed support for the removal of certain Brucella species from the select agent list, citing the potential to enhance research on vaccines and diagnostic tools. However, COGR raised concerns about the proposed revisions to the definition of “release,” arguing that it is overly broad and ambiguous, potentially leading to unnecessary reporting and increased administrative burdens without measurable safety benefits. The organization recommended refining the definition to prevent redundant or unjustified reporting.
COGR also supported the proposed exemptions for Plant Protection and Quarantine (PPQ) and Veterinary Services (VS) select agents and toxins but urged the USDA to explicitly include research laboratories in these exemptions. Regarding training requirements, COGR noted that the current language is too vague about which personnel should receive training, risking both over- and under-inclusion. The association recommended clearer criteria for identifying staff needing training to ensure practical and effective implementation. In summary, COGR advocated for regulatory clarity, minimized administrative burden, and a balanced approach that maintains security while supporting the research mission of its member institutions.
