Technical Input on the National Institutes of Health's Draft Supplementary Risk Assessments and Site Suitability Analyses for the National Emerging Infectious Diseases Laboratory, Boston University: A Letter Report

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Technical Input on the National Institutes of Health’s Draft Supplementary Risk Assessments and Site Suitability Analyses

whether there is a greater risk to public health and safety from the location of the facility in one or another proposed location;

The parties acknowledge and agree that the Committee’s report will be limited to a technical review of the NIH Study, and the Contractor [NRC] will make no findings or recommendations regarding the adequacy of any determinations or decisions made by any agency or department of the U.S. Government or the State Massachusetts under NEPA [National Environmental Policy Act] or MEPA [Massachusetts Environmental Policy Act], and Contractor shall not be responsible in any way for any such decisions or determinations. The Committee will author a letter report that addresses the foregoing questions and submit this letter report to the Massachusetts Environmental Policy Act Office prior to the end of the public comment period.

Thus, the questions addressed by the Committee will solely pertain to the scientific adequacy of the risk assessment and other analytical methodologies used in the DSER and whether the report responds to the state's questions in a scientifically sound and credible manner. The Committee makes no findings or recommendations regarding the original Risk Assessment and Site Suitability Analysis document Biosquare Phase II, Boston Massachusetts. Final Project Impact Report/Final Environmental Impact Report (Fort Point Associates, 2004; hereafter referred to as FEIR) although the Committee refers to the FEIR because it provides a foundation for the DSER. This letter report addresses the foregoing questions and is submitted to you in fulfillment of the contract with the Commonwealth of Massachusetts.

The Committee’s answers to the three tasking questions are as follows:

Are the scientific analyses in the DSER sound and credible? Overall, the Committee believes that the DSER as drafted is not sound and credible.
Has the NIH identified representative worst case scenarios? The DSER as drafted has not adequately identified and thoroughly developed worst case scenarios.
Based on the comparison of risk associated with alternative locations, is there a greater risk to public health and safety from the location of the facility in one or another proposed location? The DSER does not contain the appropriate level of information to compare the risks associated with alternative locations.

It is important to recognize that these conclusions are based solely on the Committee’s technical review of the DSER, and thus they should not be viewed as statements about the risks of proposed biocontainment facilities in Boston, or in cities more generally. The Committee acknowledges the need for biocontainment laboratories in the United States, including BSL-4 laboratories, and recognizes that BSL-4 facilities are being operated in other major urban areas. The Committee’s view is that the selection of sites for high containment laboratories, whether in urban or rural areas, be supported by detailed analyses summarizing the available scientific information.

The Committee provides more detailed answers to the three task questions and recommendations that you and the NIH may wish to consider in the document that follows.

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