Abstract
The article “Transfer of Select Agents and Toxins: 2003-2013” by Shelby et al that appears in this issue describes in great detail the type and exact number of transfers of select agents, the day of the week packages were shipped, and the calendar days in transit. It also characterizes the “entities” involved in the transfers. The activities described are in response to the select agent regulations (SAR) promulgated in 19971 and 2003.2 The Centers for Disease Control's Division of Select Agents and Toxins3 (DSAT) and the US Department of Agriculture Select Agent Services4 make up the Federal Select Agent Program (FSAP), which approves and oversees transfer of agents that “pose a severe threat to public health and safety,” thereby “protecting public health and safety.”* Let's assume for the sake of this argument that the select agent regulations were brilliantly drafted, necessary, and sufficient. Shelby et al's article and the resources current and proposed to operate the select agent program, viewed in the shadows of an apparently increasing number of shipment errors in select agent labs, suggest that it might be time to revisit the implementation of the program.
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