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A risk-based framework to guide oversight of nucleic acid constructs
Audrey Cerles1, Abigail Dingus-Simmons2, Rocco Casagrande3
1Deloitte, Minneapolis, MN, United States.
Frontiers in Bioengineering and Biotechnology
|July 30, 2026
Summary
This study proposes a risk-informed framework for classifying synthetic nucleic acids, distinguishing custom from non-custom products into high, intermediate, and low-risk categories to improve biosecurity screening guidance.
Area of Science:
- Biosecurity
- Synthetic Biology
- Nucleic Acid Synthesis
Background:
- Current nucleic acid synthesis screening guidance lacks clarity, creating uncertainty for providers and policymakers regarding biosecurity oversight.
- This ambiguity can result in inadequate protection against high-risk products or unnecessary burdens on legitimate research for low-risk products.
Purpose of the Study:
- To present a risk-informed framework for classifying synthetic nucleic acid products based on biosecurity relevance.
- To inform proportionate screening guidance for synthetic nucleic acids.
Main Methods:
- Developed a three-tier classification system for synthetic nucleic acids based on input from synthetic biology and biosecurity specialists.
- Distinguished between custom and non-custom products, categorizing them into high-, intermediate-, and low-risk groups.
Main Results:
- Recommends strict scrutiny for longer DNA/RNA sequences (≥50 bp/nt), custom orders, and non-custom products from pandemic viruses or Federal Select Agent Program viruses.
- Suggests excluding very short oligonucleotides (<30 bp/nt) and non-DNA/RNA nucleic acids from routine screening.
- Identifies an intermediate-risk category for products requiring further investigation, including those incorporating nucleic acids into medical products and long viral sequences in non-custom repositories.
Conclusions:
- The proposed framework aims to align synthesis screening oversight with significant biological risks.
- Highlights evidence gaps and areas for future investigation in nucleic acid biosecurity.
- Provides a structured approach to manage biosecurity risks associated with synthetic nucleic acids.

