Since Kansas  was chosen to host DHS’s behemoth of all bio-labs, (we are still waiting on the official word from Jay Cohen) there have been several on-going media discussions on the internets concerning the NBAF’s benefits to Kansas, a biotech power grab and of course the talking points (thanks to all of you guys who sent me this stuff). But few are discussing where all of the funding for the “project of the century” will come from and no one seems to be concerned about the safety deficiencies outlined in the most recent GAO report  and in a series of CRS Issues for Congress reports. An aside note: The CRSreports, specifically, have growth in length and depth of the stated issues since the first NBAF report to Congress. The most recent report focused on the NBAF draft EIS which includes information from The Rift Valley Fever Working Group. That report left me wondering if my concerns regarding select agents of study at the NBAF were directed at the wrong pathogen. Consider this;

Despite the potentially higher costs of a Rift Valley fever virus release, in terms of economic costs and human lives lost,most of the debate about mainland versus island laboratories has focused on FMD. This likely arises in part from the legal restrictions placed on such research. Currently, research on live FMD virus is statutorily limited to locations outside of the mainland of the United States.

Regardless of what type or where the research is preformed it must be done using the safest methods not the most cost effective. Kansas, (like most states) is dealing with huge budget shortfalls and the NBAF is one facility where the “national priority” is the funding. Without proper funding the first thing that will be compromised is the safety. That said, DHS is known for its ole, funding debacles and  its “bait and switch” approach to projects. But I, like many of the lab opponents hold out hope with the 500 lbs gorilla in the room which is the requirement that DHS has yet to satisify or meet; Plain and simple, DHS dosen’t have the evidence that research on FMD can be done safely and securely on the mainland. 

The GAO report stated – A comprehensive analysis to determine if FMD work could be conducted safely on the U.S. mainland would have considered these points, at a minimum. DHS did not identify or remedy these deficiencies before using the USDA study to support its conclusions. Consequently, we believe DHS does not have evidence to conclude that FMD work can be done safely on the U.S. mainland.

Thus no funding:

 As reported by the House Committee for Appropriations, the Department of Homeland Security Appropriations Act, 2009 (H.R. 6947) would forbid the use of FY2009 appropriated funds for design or construction of NBAF on the mainland until the DHS completes a risk analysis of whether foot-and-mouth disease work can be done safely on the United States mainland and until the Government Accountability Office (GAO) reviews this risk assessment.

Okay, so look at the why from 2 perspectives. 1) The 2002 study DHS is relying on was started by the USDA and completed by Science Applications International Corporation (SAIC). In my opinion, there are several reasons for concern, SAIC and its subsidiaries have a certain duty to make their clients happy while making their shareholders money. As you can see  in the POGO’s Federal Contractor Misconduct Database, they have been successful at both. In fact SAIC is in the top 10 list at #9 and its subsidiary Bechtel Corporation appears at # 14.

2) The GAO found that: 

SAIC, United States Department of Agriculture Biocontainment Feasibility Studies, Study Report. The study examined a number of other questions concerning a possible move of PIADC to the mainland, in addition to the questions on technical feasibility regarding biosafety and biosecurity.

 Among other things, (1) the study used an ad hoc method to select its expert panel that was not necessarily free from bias; (2) the study report was written by a single third-party person under contract for that purpose who was not present during the panel discussions; and (3) no concern was taken to ensure that the expert panel members reviewed either the draft or the final version of the report. At least one expert panel member expressed disappointment with the slant of the report.

 In addition to a number of other methodological problems with the study, we found that it was selective in what it considered in order to reach its findings. In particular, the study

1. did not assess the history of releases of FMD virus or other dangerous pathogens,

 2. did not address in detail the issues related to large animal work in BSL-3 Ag facilities, and

  3. was inaccurate in comparing other countries’ FMD work experience with that of the United States.

Clearly the GAO saw some red flags and given the nature of the stated risk, don’t you think it is a good idea the study be preformed from an entity that didn’t have a vested interest in the result of the report? Yes, so before the corks are popped on the champagne lets first put the 500 lbs. gorilla to bed.

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