Response to Recommendations on US Policy Governing Potential Pandemic Pathogen and Dual Use Research

September 21, 2022 – A group of scientists, public health experts, and policy researchers responded to the preliminary draft recommendations from the National Science Advisory Board on Biosecurity (NSABB) regarding the US government’s policy for oversight of research involving enhanced potential pandemic pathogens (ePPP) and life sciences dual-use research of concern (DURC).*

In early July 2022, 34 experts submitted “Recommendations to Strengthen the US Government’s Enhanced Potential Pandemic Pathogen Framework and Dual Use Research of Concern Policies” to NSABB, the US National Institutes of Health (NIH), and the White House National Security Council and Office of Science and Technology Policy to provide insight into a US government policy review process that is now underway.

A letter based on the July recommendations was submitted to the NSBB in response to its recently released document on the NIH website, “Preliminary Draft Findings & Recommendations.” The letter commends many of the recommendations made in the NSBB’s preliminary draft thus far, while also expressing serious concern over important gaps and shortcomings. For instance, the signatories recommend broadening the scope of the draft framework to include additional types of research, establishing oversight of sequence information, and increasing transparency in the oversight and review process.

“The recommendations noted are highly important elements of a strong and clear governance framework for ePPP research and DURC experiments,” the letter states. “Incorporating these recommendations into the final NSABB document will help diminish the risk that US science could inadvertently initiate epidemics or pandemics while minimizing disruption of scientific work that does not pose this risk; clarify the scope and decision-making process; and increase transparency around US policy and decision-making on these issues.”

Read the September 20 letter.

*For the purpose of the recommendations, the experts refer to the “ePPP Framework” as consisting of both the White House Office of Science and Technology’s (OSTP) “Recommended Policy Guidance for Departmental Development of Review Mechanisms for Potential Pandemic Pathogen Care and Oversight (P3CO)” and the US Department of Health and Human Services’ (HHS) “Framework for Guiding Funding Decisions about Proposed Research Involving Enhanced Potential Pandemic Pathogens.”