AAAS and Partners Urge Clarity in U.S. Oversight of Dual-Use Research

In comments on a draft framework for dual-use biological research, AAAS and five partner organizations have asked the National Science Advisory Board for Biosecurity to provide more clarity on the types of research with potential for misuse and urged broader outreach by the board and federal agencies prior to setting up any oversight system.

Dual-use research is work that has legitimate scientific value, including various microbiological experiments, such as in genetics and biotechnology, but which also has the potential to be misused for nefarious purposes such as bioterrorism. The NSABB was established to provide advice to federal departments and agencies on ways to minimize the possibility that knowledge and technologies arising from important biological research will be misused to threaten public health or national security.

The 15 July comments to NSABB were submitted in conjunction with a meeting that day by the Board regarding its draft framework, released in June 2007, on ways to provide federal oversight of dual-use research.

The organizations applauded the board's statement that any restriction on scientific communication should be the rare exception rather than the rule. But the organizations also urged NSABB and federal agencies to do greater outreach to the scientific community before establishing any oversight system for dual-use research. They called for more detail on the types of research that might fall under the umbrella of concern and more specific directions on how research organizations, institutions, and individual researchers should comply with dual-use policies.

"Because the NSABB document is unclear regarding liability issues surrounding dual-use research," the comment letter said, "investigators or institutions may choose to forego certain research rather than risk liability."

In its draft report, the NSABB notes that its recommendations are not intended as guidelines but rather as a framework for the development—by the federal government—of a comprehensive system for the responsible identification, review, conduct, and communication of dual use research.

AAAS and its partners urged the administration to employ the federal rulemaking process, with its requirements for public comment, before implementing any of the recommendations laid out in the NSABB report.

In addition to AAAS, the organizations that joined in the comment letter to the NSABB were the Association of American Medical Colleges; the Association of American Universities, the Council on Governmental Relations, the Federation of American Societies for Experimental Biology, and the National Association of State Universities and Land-Grant Colleges.

The NSABB is chartered to have up to 25 voting members with a broad range of expertise in molecular biology, microbiology, infectious diseases, biosafety, biodefense, and related fields. The NSABB also includes nonvoting ex officio members from 15 federal agencies and departments.

Earl Lane

22 July 2008