OMB Approves CDC Final Rule on Select Agents and Toxins Update

Yesterday the OMB’s Office of Information and Regulatory Affairs (OIRA) announced that it had approved a final rule from the HHS’ Centers for Disease Control and Prevention (CDC) on “Possession, Use, and Transfer of Select Agents and Toxins; Biennial Review of the List of Select Agents and Toxins”. This rulemaking is typically coordinated the USDA’s APHIS final rule on “Biennial Review and Republication of the Select Agent and Toxin List” which was recently approved by OMB. This final rule was sent to OIRA on October 3^rd, 2024. An advanced notice of proposed rulemaking (ANPRM) was published on March 17^th, 2020. The notice of proposed rulemaking (NPRM) was published on January 30^th, 2024.

According to the Spring 2024 Unified Agenda entry for this rulemaking:

“The Bioterrorism Preparedness Act requires that the Department of Health and Human Services (HHS) Secretary review and republish the list of select agents and toxins on at least a biennial basis. This final rule concludes the biennial review and republication of the list of biological agents and toxins regulated by HHS.”

I will probably not be covering these two select agent rules in any detail here. I will at least include a note in the appropriate ‘Short Takes’ post when they are published. 

APHIS and CDC send Bio-Toxin Final Rules to OMB

Yesterday, OMB’s Office of Information and Regulatory Affairs (OIRA) announced that it had received final rules from USDA’s Animal & Plant Inspection Service (APHIS) and the CDC relating to the updating of the Select Agent and Toxin List. These are coordinated rulemakings.

APHIS Final Rule

The APHIS final rule notice is on “Agricultural Bioterrorism Protection Act of 2002; Biennial Review and Republication of the Select Agent and Toxin List”. The notice of proposed rulemaking was published on January 30^th, 2024.

According to the Spring 2024 Unified Agenda entry for this rulemaking:

“In accordance with the Agricultural Bioterrorism Protection Act of 2002, we are proposing to amend and republish the select agent and toxin lists that have the potential to pose a severe threat to animal or plant health, or to animal or plant products. The Act requires the biennial review and republication of the list of select agents and toxins and the revision of the list as necessary. This action would implement findings of biennial review of the lists. In addition, we are proposing to codify operational procedures and policies necessary to enforce the regulations. On April 8, 2022, APHIS sent tribal nations a letter outlining the provisions of the proposed rule and soliciting their feedback. On May 5, 2022, the Sac and Fox Tribe of the Mississippi in Iowa submitted a response expressing concerns regarding whether possible Brucella abortus delisting would materially adversely impact APHIS' domestic quarantine program for the control and eradication of brucellosis in cattle and bison. In response, APHIS clarified that the two issues were distinct, and no adverse operational impacts were anticipated. On June 6, 2022, the Tribe indicated that they had no further comments or concerns.”

CDC Final Rule

The CDC final rule notice is on “Possession, Use, and Transfer of Select Agents and Toxins; Biennial Review”. The notice of proposed rulemaking was published on January 30^th, 2024.

According to the Spring 2024 Unified Agenda entry for this rulemaking:

“The Bioterrorism Preparedness Act requires that the Department of Health and Human Services (HHS) Secretary review and republish the list of select agents and toxins on at least a biennial basis. This final rule concludes the biennial review and republication of the list of biological agents and toxins regulated by HHS.”

HHS and Ag Dept Publish Select Agents and Toxins NPRMs

Today the Department of Health and Human Services (CDC) as well as the Department of Agriculture (APHIS) issued separate notices of proposed rulemakings updating their respective regulations regarding select biological agents and toxins in the Federal Register (CDC: 89 FR 5823-5842; APHIS: 89 FR 5795-5819). Both departments deleted agents from their respective lists and made other modifications to their regulations. The advanced notices of proposed rulemakings (ANPRMs) were published in 2015.

There are two separate select agent/toxins lists maintained by these agencies based on separate congressional mandates. The CDC list is specifically for targeting agents and toxins that affect humans while the APHIS list is for those targeting plants and animals. There is some overlap between the two lists.

Both agencies are soliciting public comments on the proposed rules. Comments are due on April 1^st, 2024. Comments may be submitted via the Federal eRulemaking Portal (www.Regulations.gov):

• HHS Docket: CDC-2020-0024, or

• DA Docket: APHIS-2019-0018

OMB Approved Bioterrorism NPRMs – 1-5-24

Yesterday, the OMB’s Office of Information and Regulatory Affairs (OIRA) announced that it had approved a notice of proposed rulemaking (NPRM) from the Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) for “Agricultural Bioterrorism Protection Act of 2002; Biennial Review and Republication of the Select Agent and Toxin List”. The NPRM was sent to OIRA on July 26^th, 2023.

According to the Fall 2023 Unified Agenda entry for this rulemaking:

“In accordance with the Agricultural Bioterrorism Protection Act of 2002, we are proposing to amend and republish the select agent and toxin lists that have the potential to pose a severe threat to animal or plant health, or to animal or plant products. The Act requires the biennial review and republication of the list of select agents and toxins and the revision of the list as necessary. This action would implement findings of biennial review of the lists. In addition, we are proposing to codify operational procedures and policies necessary to enforce the regulations. This action was vetted with Tribal nations, and APHIS has subsequent conversations with one Tribal nation in order to ensure the provisions would not adversely affect them.”

A companion rulemaking sent to OIRA on the same day from HHS’s Centers for Disease Control and Prevention (CDC) on “Possession, Use, and Transfer of Select Agents and Toxins; Biennial Review” was also approved by OIRA.

According to the latest Unified Agenda entry for that rulemaking:

“The Bioterrorism Preparedness Act requires that the Department of Health and Human Services (HHS) Secretary review and republish the list of select agents and toxins on at least a biennial basis. This document begins the biennial review and republication of the list of biological agents and toxins regulated by HHS.”

These two NPRM’s will almost certainly be published in the Federal Register on the same day, probably in the coming week. 

CDC Publishes Request for Comments on HCl IDLH

Today, the CDC published a request for comments in the Federal Register (88 FR 54319-54320) for “Request for Public Comment on the Draft Immediately Dangerous to Life or Health (IDLH) Value Document for Hydrogen Chloride”. The draft document is available online, the 2014 version is available on the NIOSH website.

The CDC is soliciting public input on six specific questions:

1. Does this document clearly outline the health hazards associated with acute (or short-term) exposures to the chemical? If not, what specific information is missing from the document?

2. Are the rationale and logic behind the derivation of an IDLH value for a specific chemical clearly explained? If not, what specific information is needed to clarify the basis of the IDLH value?

3. Are the conclusions supported by the data?

4. Are the tables clear and appropriate?

5. Is the document organized appropriately? If not, what improvements are needed?

6. Are you aware of any scientific data reported in government publications, databases, peer-reviewed journals, or other sources that should be included within this document?

Comments may be submitted via the Federal eRulemaking Portal (www.Regulations.gov; docket # CDC–2023–0057). Comments should be submitted by October 10^th, 2023.

 

Bioterrorism Rule Updates Sent to OMB

Yesterday, the OMB’s Office of Information and Regulatory Affairs (OIRA) announced that it had received two notices of proposed rulemakings (NPRMs) supporting biennial updates required by the bioterrorism acts. NPRMs were received from Agriculture Department’s Animal and Plant Health Inspection Service (APHIS) the CDC.

According to the Spring 2023 Unified Agenda entry for the APHIS rulemaking:

“In accordance with the Agricultural Bioterrorism Protection Act of 2002, we are proposing to amend and republish the select agent and toxin lists that have the potential to pose a severe threat to animal or plant health, or to animal or plant products. The Act requires the biennial review and republication of the list of select agents and toxins and the revision of the list as necessary. This action would implement findings of biennial review of the lists. In addition, we are proposing to codify operational procedures and policies necessary to enforce the regulations.”

According to the Spring 2023 Unified Agenda entry for the CDC rulemaking:

“The Bioterrorism Preparedness Act requires that the Department of Health and Human Services (HHS) Secretary review and republish the list of select agents and toxins on at least a biennial basis. This document begins the biennial review and republication of the list of biological agents and toxins regulated by HHS.”

OMB Approves TWIC Reader Delay Rule

Yesterday the OMB’s Office of Information and Regulatory Affairs (OIRA) announced that it had approved the Coast Guard’s final rule on TWIC Reader Requirements; Delay of Effective Date. This rule regards the use of Transportation Workers Identification Credential (TWIC) readers at a limited number of facilities that handle certain dangerous cargoes (CDCs) in bulk or receive vessels carrying CDC in bulk. The notice of proposed rulemaking for this rule was published in June of 2018.

This is remarkably quick action by OIRA as the final rule was just sent to them last week. This may mean that we will see this sooner rather than later in the Federal Register.

Coast Guard Publishes TWIC Reader Delay NPRM

Yesterday the Coast Guard published a notice of proposed rulemaking (NPRM) in the Federal Register (83 FR 29067-29081) proposing to delay for a set of specific facilities and vessels the implementation date of the TWIC Reader Rule. The reason for this rule is an industry petition [.PDF download] that questions the inclusion of these facilities and vessels in Risk Group A. The three-year delay in the implementation date for just these facilities and vessels will allow the Coast Guard to review the Risk Group A assessment standards and initiate a new rulemaking if required.

The Petition

The industry petition stated (pg 2):

“Specifically, the petition requests the Coast Guard to promptly initiate a rulemaking that would amend the final rule to conform its coverage of “facilities that handle Certain Dangerous Cargoes (CDC) [Definition link added] in bulk” to those portions of facilities where the transfer to or from a vessel of CDCs in bulk occurs or is capable of occurring. This revised scope would be consistent with long-standing Coast Guard policy regarding CDC facilities and the requirement of a maritime nexus.”

The concern is that there are some facilities that have handle CDC in bulk (via truck or railroad) but those handling facilities have nothing to do with the maritime activities at the facility. Since the risk that the Coast Guard is responsible for mitigating is the risk of a maritime transportation security incident and these CDC activities have no maritime nexus, the TWIC Reader Rule should not apply to these facilities.

The Response

The Coast Guard is not currently judging the merits of the petition. It does acknowledge, however, that additional study is needed. The Coast Guard needs to determine if a more limited definition of CDC handling facilities needs to be included in the regulations or if specific guidance needs to be established to allow for a consistent waiver process to identify facilities without a maritime nexus for a transportation security incident that could be exempted from the TWIC Reader Rule requirement.

The three-year extension of the TWIC Reader Rule for CDC handling facilities that do not transfer CDC cargos to or from a vessel will allow the Coast Guard to further study the matter and initiate a new rulemaking if required.

The NPRM would modify the sub-paragraphs of 33 CFR 105.253(a) to change the description of the affected parties to the TWIC Reader Rule by adding verbiage to identify the status of a facility with respect to its transfer of CDC to or from a vessel. It would be changed to read:

“(1) Beginning August 23, 2018: Facilities that receive vessels certificated to carry more than 1,000 passengers.

“(2) Beginning August 23, 2018: Facilities that handle Certain Dangerous Cargoes (CDC) in bulk and transfer such cargoes from or to a vessel.

“(3) Beginning August 23, 2021: Facilities that handle CDC in bulk, but do not transfer it from or to a vessel.

“(4) Beginning August 23, 2021: Facilities that receive vessels carrying CDC in bulk but, during the vessel-to-facility interface, do not transfer it from or to the vessel.”

Public Comments

The Coast Guard is soliciting public comments on this proposed rulemaking. Comments may be submitted via the Federal eRulemaking Portal (www.Regulations.gov; Docket # USCG-2017-0711). Because of the short time frame until the TWIC Reader Rule goes into effect on August 23^rd, 2018, comments must be submitted by July 23^rd, 2018.

Commentary

The petition that prompted this NPRM inadvertently raises again the issue of the exemption from the Chemical Facility Anti-Terrorism Standards (CFATS) program for facilities covered by the Maritime Transportation Security Act (MTSA). The crafters of the CFATS authority (both the initial authorization in the 2006 DHS spending bill and the subsequent re-authorization in 2014) recognized that there was no need for the CFATS program to regulate facilities that were already covered under the MTSA.

The Coast Guard has long allowed facilities a certain amount of leeway to define the perimeter of the MTSA covered facility. While the waterfront facing portion of the facility is certainly covered by the MTSA rules, facilities have been encouraged to include the remaining portions of the facility in their security plans as part of an unofficial defense-in-depth approach to preventing attacks on the clearly maritime portion of the facility.

It would appear from this petition and the Coast Guard’s response in the form of this NPRM that there has been an expectation in the industry that the Coast Guard would be more lenient in their security requirements for portions of the facility more removed from the maritime transportation nexus of the facility. Never having worked at an MTSA covered facility I cannot personally testify to the accuracy of this expectation, but it would appear to me to be a reasonable approach by the Coast Guard.

Unfortunately, this would mean that significant portions of many larger MTSA facilities would not be under the same sort of security regime that either the maritime facing portion of the facility or facilities regulated under the CFATS program. This would be especially true for portions of the facility that did not contain CDC but did store, produce, or handle chemicals that are identified as theft/diversion chemicals of interest under the CFATS program.

During the reauthorization of the CFATS program that needs to take place this year, Congress needs to specifically re-look at the blanket exemption MTSA covered facilities are give to the CFATS program. I certainly do not advocate a wholesale voiding of that exception. The Coast Guard is the obvious agency to regulate security at the strictly maritime facing portions of the facility and has a legitimate interest in the security at the remaining portions of connected facilities since that has a direct impact on the security of the waterfront.

What the Congress needs to do is to craft a closer working relationship between the Coast Guard and the CFATS’ Infrastructure Security Compliance Division to ensure that there are adequate security measures at these MTSA facilities for theft/diversion security threat chemicals that are precursors for improvised chemical munitions and/or explosives.

A relatively simple way to do that would be to require MTSA covered facilities to submit Top Screen’s to ISCD to allow ISCD to do a full chemical-terrorist threat assessment for the facility. Then instead of notifying the facility that it was a covered facility under CFATS where it would normally be appropriate to do so, it would notify both the MTSA covered facility and the local Captain of the Port that the facility’s security plan should address the security measures necessary to protect the identified DHS chemicals of interest at the facility. The Coast Guard would then be responsible for regulating the security for those chemicals as part of its oversight of the existing MTSA mandate.

Select Agents and Toxins Update ANPRMs

In separate rulemaking activities today the Centers for Disease Control (CDC) and the Animal and Plant Health Inspection Service (APHIS) both published advance notices of rulemaking (ANPRMs) in today’s Federal Register concerning the updating of the Select Agent and Toxins list. The CDC action (80 FR 10556-10558) and the APHIS action (80 FR 10527) are both routine biennial reviews mandated by Congress.

There are two separate lists maintained by these agencies based on separate congressional mandates. The CDC list is specifically targeting agents and toxins that affect humans while the APHIS list is for those targeting plants and animals. There is some overlap of the two lists.

The CDC is considering removing six agents from the HHS List of Select Agents and Toxins:

● Coxiella burnetii;

● Rickettsia prowazekii;

● Bacillus anthracis Pasteur Strain; and

● Brucella abortus, B. melitensis, and B. suis

APHIS is not currently considering the addition or deletion of any specific agent or toxin from their List of Select Agents or toxins.

Both agencies are soliciting public comments. Comments may be submitted via the Federal eRulemaking Portal (www.Regulations.gov); CDC comments would be filed under docket CDC-2015-0006 and APHIS comments under docket APHIS-2014-0095. Comments for both ANPRMs should be filed by April 28^th, 2015.

Coast Guard Publishes TWIC Reader NPRM

On Friday the Coast Guard published a notice of proposed rulemaking in the Federal Register (78 FR 17781-17833) regarding the requirements for the use of a TWIC Reader at MTSA covered vessels and facilities. Public comments on the NPRM are being solicited.

Risk-Based Deployment

The Coast Guard is taking a risk-based approach to targeting the required deployment of TWIC Readers. Coast Guard and TSA experts conducted a risk-based analysis of MTSA-regulated vessels and facilities to assess the risk of a transportation security incident (TSI). That analysis assessed three factors:

• Maximum consequences to that vessel or facility resulting from a terrorist attack;

• Criticality to the nation's health, economy, and national security; and

• Utility of the TWIC in reducing risk.

Based upon this risk analysis the Coast Guard developed three risk groups (Risk Group A, Risk Group B, and Risk Group C) that it would use to manage the requirements for deployment of TWIC Readers. In this NPRM the Coast Guard is only considering mandating TWIC Reader deployment to vessels and facilities falling under the criteria for Risk Group A. Future rulemakings may be used to expand that requirement.

Risk Group A

The Coast Guard has developed fairly simple operational definitions of what vessels and facilities fall into Risk Group A. For vessels this definition is based upon the hazardous nature of the cargo carried or the number of passengers carried. Similarly, for facilities the definition revolves around the nature of the hazardous materials (Certain Dangerous Cargo- CDC – 33 CFR 160.204) handled or the number of passengers accessing the facility.

Risk Group A Vessels -

• Vessels that carry CDC in bulk;

• Vessels certificated to carry more than 1,000 passengers; or

• Vessels towing one of the above.

Risk Group A Facilities –

• Facilities that handle CDC in bulk;

• Facilities that receive vessels certificated to carry more than 1,000 passengers; or

• Barge fleeting facilities that receive barges carrying CDC in bulk.

Use of TWIC Reader

Risk Group A vessels and facilities would be required to use TSA approved TWIC Readers to verify identity and to authenticate and validate the TWIC. For vessels this would be required upon boarding the vessel. For facilities it would be required before being granted unescorted access to secure areas.

Identity would be verified by comparing the individual’s fingerprint against one of the two fingerprint exemplars encoded in the TWIC. For facilities that are using a Physical Access Control System (PACS) that utilizes an alternative biometric identification (retina scan, for instance) “the TWIC would need to be read and the stored biometric identifier matched against the TWIC-holder's fingerprint at least once, when the individual's information is entered into the PACS” (78 FR 17792).

Card validation would be done by the TWIC Reader comparing the TWIC data against the Canceled Card List (CCL), thus requiring the TWIC Reader to periodically download the CCL. While at MARSEC level 1, this would need to be accomplished on a weekly basis. At MARSEC levels 2 and 3 daily updates would be required.

Public Comments

The Coast Guard is planning on holding at least one public meeting on this NPRM, but a date and location have yet to be determined. An announcement of the meeting will be published in the Federal Register.

The Coast Guard is soliciting public comments on the NPRM. Comments may be submitted via the Federal eRulemaking Portal (www.Regulations.gov; Docket # USCG-2007-28915). Comments should be submitted by May 21^st, 2013.

9th Coast Guard District Extends CDC Barge Reporting Suspension

The Coast Guard published a notice in today’s Federal Register (78 FR 4788-4790) that the 9^th Coast Guard District was extending the suspension of the Regulated Navigation Area (RNA) reporting requirements for barges carrying certain dangerous cargo (CDC) through September 30^th, 2013. This is an almost identical notice to the one published by the 8^th Coast Guard District Commander earlier this month upon which I have already reported.

The 9^th CG District covers the Great Lakes region.

This notice is actually a little more than a week late since the ‘current’ suspension expired on January 15^th, a little over a week ago.

CG Continues Suspension of CDC Reporting Requirement

The Coast Guard published a notice in today’s Federal Register (78 FR 25-27) continuing the current suspension of certain dangerous cargo (CDC) barge reporting requirements (33 CFR 165.830) in the inland waterways of the 8^th Coast Guard District (essentially the US waterways that drain into the Gulf of Mexico). This suspension was originally put into place via a 2011 notice in the Federal Register (76 FR 1360-1362).

RNA Established

The initial establishment of this regulated navigation area (RNA) and its associated reporting requirements was done in 2003 (68 FR 57358-57365). According to the summary of that interim final rule:

“This action is necessary to ensure public safety, prevent sabotage or terrorist acts, and facilitate the efforts of emergency services and law enforcement officers responding to terrorist attacks.” 68 FR 57358

There is a lengthy description of what types of chemicals are included under the term CDC in the definition section of 165.830(c). They include toxic inhalation hazard (TIH) gasses and liquids that are also considered TIH chemicals, as well as a variety of explosives and radioactive materials. In short materials that could be released as improvised chemical weapons or improvised explosive devices if attacked by terrorists.

In the background and purpose of that rule the Coast Guard went on to explain that:

“The RNA affects vessels transporting barges loaded with CDCs that if used as weapons of terrorism could result in substantial loss of life, property, environmental damage, and grave economic consequences.” 68 FR 57359

Reason for Suspension

The reporting requirements of the interim final rule were suspended when the contract for the operation of the CDC Barge Reporting System at the Inland River Vessel Movement Center (IRVMC) expired. Since there was no system available for tracking the reported CDC barge information, the Coast Guard decided that suspending those requirements was appropriate.

The initial suspension was for two years to allow the Coast Guard to “analyze future reporting needs and evaluate possible changes in CDC reporting requirements” (76 FR 1360). At the time the Coast Guard’s stated options were:

• Lift the suspension and restore the obligation of the affected public to comply with the existing reporting requirements;

• Modify those requirements, or

• Repeal the RNA.

According to this notice that review is still on-going and the suspension will continue in effect until September 30, 2013.

Public Comments

The Coast Guard is not actively soliciting public comments on this rule because the Coast Guard expects that “the affected public will have no objection to the extension of the temporary suspension of regulatory requirements” (78 FR 25-26). I would assume that the owner/operators that move CDC barges along the affected waterways are the ‘affected public’ in this case; and no, they would certainly not object to a continuation of the current suspension.

What is not so clear is what the potential concerns are of the people living and working along those waterways that might be affected by a terrorist attack on these CDC barges. Those were the people that the original interim rule was designed to protect. They might have cause to comment and the Coast Guard has made provisions to allow them to do so.

 

Comments may be submitted via the Federal eRulemaking Portal (www.Regulations.gov; Docket # USCG-2012-1074). Since the effective date of this temporary final rule is January 15^th, the typical ‘comment by date’ does not apply as the Coast Guard has made no provisions for responding to those comments before this suspension extension goes into place.

CG Establishes Maritime Security Zones for RNC

Today the Coast Guard published a temporary final rule in the Federal Register (77 FR 50926-50929) concerning security zones for vessels carrying certain dangerous cargo. This rule is being issued as part of the DHS security support for the Republican National Convention taking place in Tampa, FL from August 25, 2012, through August 31, 2012.

While the term ‘certain dangerous cargo’ (CDC) may apply to a variety of extremely hazardous chemicals on vessels, the rule makes it clear that it specifically applies to only to vessels carrying “carrying anhydrous ammonia, liquefied propane gas, and ammonium nitrate” {77 FR 50927}. These are common bulk chemicals that transit Tampa Bay. Such CDC vessels will be escorted by Coast Guard vessels during their transit of the area.

Instead of requiring such CDC vessels to stay away from the Port of Tampa Bay during the Convention, the rule establishes a moving security zone around such vessels as they move through the Port area. The discussion in the rule notes that:

“Security measures have been limited to the minimum necessary to mitigate risks associated with the identified threats.” {77 FR 50927}

Because of the short notice period, there has not been a public comment period provided for this rule. Anyone with questions about the rule should contact Marine Science Technician First Class Nolan L. Ammons; D07-SMB-Tampa-WWM@uscg.mil.

New Flu Strain

Just because there aren’t enough hackers, cyber-vulnerabilities, and just plain terrorists to keep security managers awake at night, according to an blog at ABCNews.com the CDC has announced that a new strain of our favorite wet-ware virus has been reported in circulation. The flu bug is always coming up with new ways to cause problems; due in no small part to it plagiaristic attitude towards DNA.

Flu cognoscenti keep track of the basic strains of the flu with a four character code HxNy. Most will remember the H5N1 bird flu concern of a couple of years back (it’s still there floating around killing hundreds of people every year, small potatoes for the flu). Then there was the H1N1 pandemic of just two years ago (a much higher death rate, but not anywhere near the 1917 flu pandemic).

New H3N2 Strain

The new strain of potential concern is a variant of the H3N2 virus that has been found in pigs in North America. Apparently some pig had the temerity to become infected with both the H3N2 and the H1N1 at the same time and the two strains of viruses exchanged gene segments. Typically animal strains of the flu don’t transmit well to humans nor do they make the human-to-human transfer that is necessary for a wide spread outbreak.

Earlier this month this new strain of H3N2 (technically S-OtrH3N2) apparently made the transition to a transmissible form of the bug. Three children in Iowa came down with the bug after appearing at the same event (their only link). More importantly, none of the kids or their families has had any contact with live pigs.

CDC’s Concerns

Now three patients is certainly a far distance away from an epidemic and even further from a pandemic. What has the CDC concerned, however, is that the current flu vaccine did not include this strain (they made the choice of strains for this winter’s vaccine last spring) and it doesn’t appear likely that the vaccine will be terribly effective against this new strain, particularly in children.

To raise concerns further, two of the common anti-viral medications used for treatment of the flu, rimantidine and amantadine are not effective with this strain, though Tamiflu and Relenza both appear to be effective. The folks at the CDC would prefer not to use those two drugs as they don’t want the bugs to build up immunity to these two powerful antivirals.

Flu and Security

Both human resources and security management need to keep an eye on the progress of the flu season in general and new strains specifically. Both are going to find it difficult to keep up minimum staffing levels if large numbers of people are out with the flu. Contingency plans need to be made to deal with the potential shortages of personnel. And remember, while manufacturing can reduce shifts or work days, the security will have to be there regardless.