E. M. Davidson et al., in their Policy Forum, "Practical experiences in dual-use review" (8 June 2007, p. 1432) provide useful empirical data for policymakers and those in the science and security communities trying to develop an oversight system for dual-use life sciences research (i.e. research that can support both peaceful and hostile applications).
The experiences of the Southeast Regional Center of Excellence for Emerging Infections and Biodefense (SERCEB), and the decisions of two of its participating universities to implement institutional level oversight based on objective criteria for identifying potential dual-use research, stand in marked contrast to the recent recommendations of the National Science Advisory Board on Biosecurity (NSABB) (1). The NSABB recommends that individual researchers be responsible not only for determining whether their research has dual-use potential, but also for determining whether the level of risk merits further institutional review. The process would be subjective and dependent on a single individual. It has no mechanism to assess, let alone enforce, compliance (for additional comments on the NSABB recommendations, see reference 2).
But as Davidson et al. point out, few life scientists understand or are even aware of the dual-use dilemma, and it is those researchers who are least sensitive to dual-use concerns who may pose the greatest risk and thus be most in need of independent dual-use review. There is another problem as well—while the triggers for dual-use review should be objective, the risk assessment process itself will be more subjective. Different people may make very different assessments, and a range of expertise will be needed that no one individual can provide. For these reasons, independent, group-level review is necessary.
To be effective, oversight will need to extend to all government conducted or sponsored research, and ultimately to all privately funded research. It will also need to include compliance mechanisms and mechanisms for elevating particularly difficult dual-use concerns to national level review. The Institutional Biosafety Committee system will either have to be repaired [it works at some institutions, but not at others (3)] and have its mandate extended to include dual-use research review, or some other mechanism will need to be developed. All of this will require money–setting aside 2% of the annual biodefense research budget for this purpose [roughly $60 million/year (4)] for several years is not too much to ask for so important a purpose.
All too often in current debates about research oversight, a wedge is placed between supporting the advancement of the life sciences on the one hand and preventing the malevolent use of the life sciences on the other. But in fact, oversight of life sciences research supports public health; it is the lack of oversight which contributes to public health threats today. Scientists are legitimately concerned that an oversight system could go too far. SERCEB’s experiences, and experiences with other mandatory oversight systems in other countries (5), demonstrate that oversight need not be too onerous.
Alan Pearson
Biological and Chemical Weapons Control Program, Center for Arms Control and Non-Proliferation, Washington, DC, USA.
References
1. “Draft Report of the NSABB Working Group on Oversight Framework Development,” (19 April 2007) at http://www.biosecurityboard.gov/NSABB%20Draft%20DUR%20Ov%20Framewk8%20for%20public%20posting%20041907%20mtg2.pdf (accessed 15 June 2007).
2. Public comments on the NSABB Oversight Framework are available at http://www.armscontrolcenter.org/resources/20070419_nsabb_public_comments.pdf (accessed 26 June 2007).
3. The Sunshine Project, “Mandate for Failure: The State of Institutional Biosafety Committees in an Age of Biological Weapons Research,” (4 October 2004) at http://www.sunshine-project.org/ (accessed 15 June 2007).
4. Center for Arms Control and Non-Proliferation, “Federal Funding for Bioweapons Prevention and Defense, Fiscal Years 2001 to 2008,” (6 June 2007) at http://www.armscontrolcenter.org/archives/002289.php (accessed 15 June 2007).
5. F. Lentzos, Biosecurity and Bioterrorism 5, 55 (2007).
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