If the United States had an effective system of reporting laboratory accidents, a situation like that engulfing the Wuhan Institute of Virology might be avoided. And, obviously, the ends of public health served. And, probably, more accidents avoided in the first place. But the United States does not have an effective system of accident reporting, and there’s little prospect of the National Institutes of Health creating one.
The potential for accidents, and here I include unintended but potentially dangerous outcomes, is the single biggest reason for the existence of the Guidelines. And the potential for those accidents to have (human, animal, or plant) health, economic, and reputational impacts on the public is the biggest reason for the existence of the Guidelines’ Public Access Provisions.
There are a lot of issues to unpack and discuss about lab accidents and their reporting. This first look is only an overview. This is not a post about any specific lab accident, although you can expect such posts in the future.
Until recently, the Recombinant DNA Advisory Committee (RAC) served as the country’s highest level review body for novel biotech research safety questions. But NIH disbanded it last year. That leaves, in most circumstances, the frequently dysfunctional local Institutional Biosafety Committees (IBCs) to be the first – and last – line of defense against really stupid ideas and screw ups.
The muckety mucks at NIH, here meeting in late 1977, were quite clear about what kinds of records Institutional Biosafety Committees are required to release to the public. God bless them. (National Library of Medicine)
The Public Access Provisions of the NIH Guidelines, as they apply to records, are short and simple. Consisting of a single paragraph, they say that Institutional Biosafety Committees (IBCs) must release to the public their meeting minutes and all other related records that their funders are required to release. Like so:
Upon request, the institution shall make available to the public all Institutional Biosafety Committee meeting minutes and any documents submitted to or received from funding agencies which the latter are required to make available to the public. If public comments are made on Institutional Biosafety Committee actions, the institution shall forward both the public comments and the Institutional Biosafety Committee’s response to the Office of Science Policy, National Institutes of Health ... – NIH Guidelines at Section IV-B-2-a-(7)
In simple terms, what this obviously means is that, in addition to minutes, if the institution holds other records* related to rDNA research that can be obtained from a government agency under the Freedom of Information Act (or other law), then the IBC has to release those records on request. And that such records exist is effectively always the case, because nobody gets a federal grant or contract without paperwork.
