NASEM Evaluates USDA Contingency Planning and Training of Personnel Rule

By: Galen Cobb
Wednesday, January 8, 2025
On January 7, the National Academies of Science, Engineering & Medicine (NASEM) presented the Proceedings in Brief from a workshop, hosted by the Roundtable on Science and Welfare of Animals Involved in Research on June 4-5, 2024, that evaluated the impact and implementation of the USDA’s APHIS Contingency Planning Rule (APHIS-2020-0101).

The rule requires all animal research facilities to have a written plan and training protocols for humane animal care and handling in an emergency or disaster. Plans are required to follow a framework of four criteria that include: 1) identifying and including reasonably anticipated emergencies; 2) outlining specific tasks; 3) establishing a chain of command for emergency response; and 4) addressing response and recovery efforts. While the rule stipulates the use of this framework, flexibility in implementation is intentionally provided to encourage institutions to create a plan consistent with their specific circumstances. APHIS provides an optional guidance document (Form 7093) to assist in developing contingency plans. Plans must be reviewed annually. Additionally, the rule requires training of all personnel under the following schedule:

• All employees must be trained on their roles and responsibilities in the plan within 60 days of implementation.
• New employees must receive training on the plan within 30 days of hire. 
• Employees must be informed of any substantive changes to the play within 30 days of the revision.

Workshop Planning Committee Chair, Susan Harper, DVM, MS, DACLAM, and Committee Vice Chair, Lesley Ann Colby, DVM, MS, DACLAM, presented the key themes of the workshop, including findings from two community surveys (one conducted by FASEB), challenges experienced in plan development and implementation, and insights into best practices for training. Generally, institutions adapted well, having pre-existing contingency plans in place that complied with the rule. Respondents who needed to generate new contingency plans reported spending more time developing plans (more than 12 to 15 hours) than the USDA had estimated (four to six hours or one to two hours when using Form 7093). One of the top reported challenges was identifying appropriate emergencies and disasters to include in the plan and creating dynamic plans that can sufficiently adapt to a wide variety of situations. Participants expressed the need for greater guidance and/or resources to assist with these challenges, e.g., example contingency plans from comparable institutions. While most institutions have implemented didactic training, there was recognition of the need for more hands-on, experiential training and the benefit this can provide for more effective emergency responses. Overall, there was strong consensus that greater collaboration across sectors, institutions, and roles is needed to address the complexities of contingency planning. 

A full copy of the report can be found here: Contingency Planning and Training of Personnel Rule: One Year of Implementation: Proceedings of a Workshop—in Brief | The National Academies Press.

Supplemental documents describing the findings of the NASEM-led survey and workshop participant suggestions for action items to improve the contingency planning process can be found here: Contingency Planning and Training of Personnel Rule (APHIS-2020-0101) One Year of Implementation - A Workshop | National Academies (listed under Resources).