for ensuring the prevention and mitigation of risks to the health and safety of laboratory workers and the public.
The committee held public meetings to gather information to address its task. It met with USAMRIID and Fort Detrick medical and safety officials, contractors involved in the development of the EIS, members of the Frederick County Board of Commissioners, and members of the general public. The committee also had separate meetings with the medical and security staff of Frederick Memorial Hospital, officials from Frederick County’s emergency management and health departments, and representatives from the community.
EISs are documents required under NEPA to identify probable environmental impacts (including health effects) from programs and actions of the Federal Government. They are required to provide full and fair discussion of significant potential environmental and health impacts and consider reasonable alternatives that would avoid or minimize adverse environmental impacts or enhance the quality of the human environment. However, there is no specific guidance for considering some of the unusual infectious disease risks from bio-containment facilities.
The hazard assessment included in the USAMRIID EIS explored a range of possible consequences that could result from a mishap at the new USAMRIID facilities. The maximum credible event (MCE) analyses (required in an EIS) involved simulation of biological aerosol releases from biosafety level (BSL)-3 and BSL-4 laboratories. In the scenarios, Coxiella burnetii (requiring BSL-3 containment) and Ebola Zaire virus (requiring BSL-4 containment) were released to the surrounding environment from an exhaust stack after vials in a centrifuge leaked and air filters failed to filter the pathogens. The EIS estimates that ground concentrations would be insignificant and would not pose a hazard to the nearby community. However, the committee was unable to verify this prediction, because the modeling performed in support of the scenarios was not transparent, could not be reproduced, and was incomplete. Specifically, the data and parameterizations used in the computerized simulation scenarios were not provided in the EIS and the model software (Hazard Prediction and Assessment Capability model) is a closed-source system not available for independent review. The committee attempted to verify the calculations using common alternative models. The committee’s calculations indicated the potential for significantly higher doses of infectious agents following puff releases than was described in the EIS.
Other problems with the MCE scenarios were the use of inappropriate scenarios and inadequate enumeration and characterization of risks. EIS guidance specifies that hazard scenarios should be “reasonably foreseeable,” but the ones used in the USAMRIID EIS required multiple failures, such as human errors (e.g., failure to use O-rings to seal the centrifuge tubes) and safety failures