Sunday, February 12, 2006

NEDC Wants Citizen Oversight of Labs

The following is text from the latest letter from the NEDC (Northeast District Council) which represents 20
neighborhoods in Seattle. The NEDC continues to lead the way in attempting to bring some democratic control
to the booming biolab situation in Seattle. You can get copies of all three letters off the website.

February 6, 2006

Seattle City Councilmembers
600 Fourth Avenue, Floor 2
P.O. Box 34025
Seattle, Washington 98124-4025

RE: Community oversight of biosafety labs in Seattle and King County

Dear Seattle City Councilmembers: President Nick Licata, Peter Steinbrueck, Jan Drago, Richard Conlin,
David Della, Jean Godden, Tom Rasmussen, Richard McIver, and Sally Clark,

The Northeast District Council, a group that represents over 20 Seattle neighborhood groups, recommends independent regulation of Seattle biosafety laboratories. Such independent oversight of biohazardous research is critical to our public health system.

We appreciate Karen Van Dusen's response on behalf of the University of Washington to our previous letter
seeking independent citizen oversight of biosafety labs. We believe that the UW is a good yardstick that one can use to measure safety at other local similar facilities. Although the UW makes a good reference point, we don’t believe the UW is doing all it can do to protect the public from future incidents or accidents.

What the community is looking for in an independent biosafety oversight committee is a group that is financially independent of those being overseen and which (by definition) represents the community, in order to foster public trust, accountability and best practice.

NIH Guidelines, which govern the operation of biosafety labs across the country, are not regulations but are as close to regulatory standards as exist for governing operation of biosafety labs. The Guidelines require Institutional Biosafety Committees [IBCs], which provide a level of transparency, of public process, and of community involvement in oversight of biosafety labs.

In particular, the Guidelines specify there be at least two community representatives on each IBC. They further specify what "community representative" means: namely, "not affiliated with the institution...and who represent the interest of the surrounding community with respect to health and protection of the environment". The Guidelines provide examples: such representatives could be "officials of state or local public health or environmental protection agencies, or persons active in medical, occupational health, or environmental concerns in the community".

One of the roles for a municipal-level oversight committee such as we are proposing would be to confirm and authenticate the representativeness of those members. In Cambridge MA, the Cambridge Biosafety Committee, one of our models for an independent oversight committee, requires that community reps have neither financial ties to the bio-tech sector nor work in an academic department which is directly associated with the biotech sector.

The UW IBC, however, lists as one "public member" an employee of Zymogenetics, who would not pass the
Cambridge conflict of interest test. Another is a former employee of the UW Environmental Health and Safety Dept., who would also flunk that test. The UW IBC includes a member of the county board of health,
who clearly does meet the standard.

When the UW RBL proposal became public a year ago, the greater Seattle community discovered that not only
were there 30 UW biosafety level 3 labs [BSL-3s] in the vicinity, but there were at least a half-dozen private such labs. A local public interest group has recently compiled a map of the known such labs, a copy of which is attached. While the UW BSL-3s are governed by the UW IBC, the others are not. Some have IBCs, some apparently do not. In any case, the NIH Guidelines only apply to labs funded by public dollars. BSLs which are privately funded apparently have no governmental oversight and are not necessarily even identified to local authorities.

Part of the point is that there is no central registry; there is no comprehensive oversight of such facilities. It is a public health issue, and our request is that an independent oversight committee, modeled upon the CBC, be set up under the auspices of the Seattle-King County Public Health Department.

Thank you for considering our request to improve our public health system.


Matthew Fox, Co-Chair Jim O’Halloran, Co-Chair