No NBAF in Kansas

Real Biosecurity for the Heartland

Comments Submitted to the National Research Council

Posted by tmanney on March 8, 2012

Comments Submitted to the National Research Council Committee on the Updated Site-Specific

Risk Assessment for the National Bio- and Agro-Defense Facility in Manhattan, Kansas

William L. Richter, Ph.D.

Professor Emeritus, Kansas State University

February 24, 2012

            I wish to thank the Committee for the excellent public hearing held at Kansas State University on Friday, January 27, 2012. The two-hour session was exceptionally fair, transparent, and considerate of all points of view.  This is in contrast to the way in which most prior discussion of NBAF has taken place – with attempts to maintain a political “united front” in support of NBAF and to stifle, dismiss or deride any criticism of that position.

            There was some concern from interested university faculty that the January 27 meeting was held 8:00-10:00 on a Friday morning, when many had teaching commitments, but I thought most of the relevant arguments both for and against NBAF were aired. I realize that your Committee is not responsible for dealing with some of the substantive objections to NBAF that were raised in the meeting, and appreciate your willingness to listen to each submission. I did not offer oral testimony at the session because I perceived that time was limited and that others had important points to make. If it is not too late to do so, I wish to submit the following written comments for your consideration because I think they are relevant to your review of the site-specific risk assessment (SSRA) and because I did not hear them presented in the oral testimony.

1.         Risk, Other Values, and Organizational Culture

            The Committee raised some important questions in the first hour of the hearing about existing Kansas State University procedures to minimize risk of accidental or intentional release of deadly pathogens. The organizational cultures of large organizations can have serious consequences, as NASA found with both the Challenger and Columbia space-shuttle disasters. The Columbia Accident Investigation Board (2003) “searched for causal principles that would explain both the technical and organizational system failures [that] were needed to explain Columbia and its echoes of Challenger….” A significant factor, the Board found, was NASA’s organizational culture.

Leaders create culture. It is their responsibility to change it. Top administrators must take responsibility for risk, failure, and safety by remaining alert to the effects their decisions have on the system…. The past decisions of national leaders–the White House, Congress, and NASA headquarters–set the Columbia accident in motion by creating resource and schedule strains that compromised the principles of a high-risk technology organization. The measure of NASA’s success became how much costs were reduced and how efficiently the schedule was met….

At least two sets of questions flow from this observation that are relevant to the Kansas NBAF enterprise: (a) What has been Kansas State University’s record in dealing with other health and safety situations? (b) How have the proponents of NBAF dealt with risk issues to date?

 

1(a)      Kansas State University’s Record of Dealing with Risk

 

            On September 22, 2010, the Topeka Capital-Journal online edition carried a story on a toxic landfill lying just west of the NBAF construction site and north of the K-State football stadium. (http://cjonline.com/news/state/2010-09-22/ksu_to_clean_toxic_landfill) “As many as 175 chemicals of varying concentration and toxicity were tossed into the university’s landfill cocktail.” “Tritium, carbon-14 and other radioactive elements were placed into the ‘Atomic Waste Burial Plot’ adjacent to the Wildcats’ football stadium from 1961 to 1987, according to a consultant’s report prepared for K-State and submitted to the Kansas Department of Health and Environment in August.” Kansas State University is spending around $4 million to remediate the site.

            About a decade earlier, in November 2001, my wife (Professor Linda K. Richter) was sickened by poisonous fumes released in Waters Hall, where she was teaching that day and where her office was located. Subsequent inquiry found that the Entomology Department had contracted with Cheney Construction to paint lab tables with substances that would make them impervious to chemical spills. The substances used in the painting were themselves highly toxic, however, and should have been used with adequate precaution when the building was not in use. Instead, Cheney Construction subcontracted the job to a local auto-painting company and that company’s workers proceeded on a day when classes were in session, without even protective masks for themselves. My wife went to the hospital emergency room. It is our understanding that at least 200 people were sickened by the fumes, that the campus safety officer did not visit the site until three days after the event, and that no action was taken against those responsible for the accident.

            Following this incident, Professor Richter checked with other departments in the building and found that most were concerned about other environmental issues, including a seemingly high incidence of cancer among faculty with offices in the building and water quality in the drinking fountains. Most departments bought bottled water because they did not trust the water fountains, but there were no signs to warn students not to drink the water. When this was reported to central administration, a survey of the water fountains in the building was conducted and it was found that 17 of the 31 machines did not have potable water. The tests were conducted after letting the water run for four minutes, something a casual user was not likely to do. The polluted machines were simply removed from the building without fanfare.

            Our neighbor, Professor Torry Dickinson found herself getting sick in Leasure Hall. When the soil in front of Leasure was tested it was found to have high concentrations of heavy metals, apparently from the nearby coal-fired power plant.  We are not aware of any remedial actions that have been taken in that part of the campus.

            Certainly, the university’s risk and safety record is mixed.  As K-State’s first Associate Provost for International Programs I initiated and oversaw in the mid-1990s the development of health and safety procedures for our study abroad participants. But I also know that proactive procedures (such as predeparture orientation) were missing or uneven before that time. The university does have a safety officer but I wonder whether the SSRA has included a careful review of his files. The question is not whether such an officer exists but the extent to which the university has procedures in place to maximize safety and minimize risk, and to what extent those procedures permeate the university.

1(b)     NBAF Proponents and Risk

            It is difficult for avid proponents of a project like NBAF to build broad-based political support for the project and at the same time deal openly with questions of risk. To welcome serious public discussion of risk would undermine the boosterism involved in the political campaign to win and pursue the project. If NASA placed concern over cost and schedule above safety, the proponents of NBAF appear to have placed institutional prestige and community economic development concerns over open discussion of risk.

 

            Several university faculty have been willing to speak out against NBAF, but several have privately confided that they are afraid to do so for fear that their grant funding will be jeopardized (given the fact that the Vice-Provost for Research has been the leading proponent of NBAF). I wonder whether those preparing the SSRA have made any attempt to get anonymous input from K-State scientists. It might be reassuring if one could find memos inviting input from faculty on risk and safety issues, but I suspect that such an invitation would have been seen as a sign of weakness in K-State’s competition with other potential NBAF sites. Any adverse comments might have been viewed as disloyalty to the “team.”

            You might find it instructive to review university news releases on the subject of NBAF over the past few years to see the lack of balance between boosterism and coverage of any of the risk issues raised by critics.

2.         Closing Comments

            Given the “team loyalty” issue mentioned above, I think it is important to offer some brief personal comments. I was a faculty member at Kansas State University for 42 years prior to my retirement in 2008. For more than half of that time I served also as an administrator in various positions from department head to associate provost. I am grateful for the many benefits and opportunities K-State has provided my wife and myself, and we have been loyal university supporters. In short, our criticism of NBAF and our raising of questions concerning the potential risk it represents to our community do not derive from any animosity to the university.  Moreover, we regard many of the proponents as friends.

            Indeed, I think it is a deeper loyalty to the institution that many are willing to offer criticism that might help avert disaster, even in the knowledge that such criticism is not welcomed by the proponents. I also think that some of the most significant improvements in the design of NBAF, such as upgrading the level of tornado that the building might withstand, would not have come about without persistent raising of risk and safety questions by NBAF critics.

            Thank you all for your Committee’s important work.         

_______________

References: Columbia Accident Investigation Report, vol. 1 (August 2003). Washington, D.C.: Government Printing Office, 2003, ch. 8, sections 8.4, 8.6, quoted selections reprinted in William L. Richter and Frances Burke, eds., Combating Corruption, Encouraging Ethics (2nd ed.  Lanham, MD: Rowman & Littlefield, 2007), p. 153. The report should also be available online at www.caib.us/news/report/default.html.

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NBAF Risk Assessment is a Theory With Limited Predictive Value

Posted by tmanney on March 8, 2012


Our Kansas congressional delegation has hailed the recently released updated Site Specific Risk Assessment for the proposed National Bio and Agro-Defense Facility (NBAF) as a confirmation of its safety.  As stated on Senator Moran’s web site, “I am pleased by the updated assessment’s confirmation of what we always knew, Manhattan is the safest and best place for this facility to be built,” Sen. Roberts said. “The de minimis risk of outbreak should help allay concerns from any opposition, in the public or Congress.”

So, as a vocal member of that opposition, I wish to share my thoughts on the updated NBAF risk assessment for release of foot-and-mouth disease virus, or any of the NBAF germs that are actually deadly to humans.  After studying the ca. 1000-page statistical modeling analysis, I cannot question its findings; it seems to be a legitimate response to Congress’s mandate. Colleagues more authoritative in their knowledge of probability theory and statistical analysis agree. But I do question and doubt the legitimacy of incomplete, uninformed, and apparently disingenuous public interpretation of the report’s findings by the administrators and politicians who seem singularly focused on bringing this facility to Manhattan at any cost.  KSU officials and the Kansas Congressional delegation, as reported nation wide, have dwelled almost exclusively on the risk of an FMD outbreak during the NBAF’s 50-year operating life being down from 70 percent to 0.11 percent.

But these interpretations have ignored 1) the caveat stated repeatedly throughout the report that the calculated probabilities cannot be taken as absolute values, 2) that statistical models are only theories and are no more accurate in predicting actual events than the assumptions that are plugged into them, and 3) the uncertainty of many of the input assumptions, and therefore of the conclusion, are extremely large.  These too are clearly stated in the report.

For example, on page 403: “it is fundamentally a modeling‐based approach and therefore has limited ability to predict the absolute probability of an outbreak occurring and the corresponding consequences.”  Statistical analysis is highly technical, intensely mathematical, and universally mysterious to ordinary people.  I have yet to read, even in the DHS report itself, an intelligible statement of what a risk of 0.11 percent actually means in the real world. Yet Senator Pat Roberts has declared that the risk is “de minimis”, which is even more obscure. One highly knowledgeable scientist explains that it means, for example, that if 10,000 identical NBAFs were built, then 10 of them would be certain to release FMD viruses over their 50-yr life times.  But as with all such probability estimates, it predicts absolutely nothing about any single case – a single NBAF.  It is just a theory.  What is worse is that the problem of understanding what a probability of 0.11 percent means in real life carries over to understanding what the uncertainty of such a value means.  The same computer model that calculated the value of 0.11 percent also calculated that there is a 95 percent chance that it could be as high as 2.5 percent.  What does that mean to you?  De minimis?

Perhaps in an attempt to help ordinary people understand these obscure, theoretical concepts, the authors converted from percent to dollars based on the economic consequences of an FMD release.  In these units they conclude, “The uncertainty (standard deviation) in the 50-year cumulative risk was found to be approximately $15B, regardless of whether catastrophic events are included.”  To me, this says the economic risk is somewhere between 0 and $15 Billion.  De minimis?

We hope that the National Research Council commission has a more realistic grasp of limits of a statistical model based on limited and uncertain input data.

Tom Manney

Professor Emeritus, Physics & Biology

Kansas State University

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NBAF in Manhattan Based on Faulty Scientific Logic

Posted by tmanney on March 8, 2012

Letter To the Editor by Gary Conrad

Neither KSU faculty nor most other working people were able to participate in the NBAF comments meeting that was held on Jan.27 at the beginning of a normal MWF teaching day (on Fridays, I have a 7:30 AM class, followed by a 9 AM meeting, so I could not attend). If the NBAF committee really wished to receive comments from the public, as well as from working KSU faculty, it could easily have been scheduled on an evening at the firehouse nearby, the conveniently accessible site of so many other similar meetings. The simplest conclusion, therefore, is that the group in charge of orchestrating this charade was not all that serious about making the meeting easily accessible to the elderly, to members of the general public, or to KSU faculty.

The essential scientific argument against locating an NBAF here is centered around the statistical likelihood of an escape of hoof & mouth (H&M) disease virus. However, no manufacturer of a “laminar flow biological safety cabinet”(the primary piece of equipment used routinely in our KSU labs, the BRI, and the NBAF, to prevent contaminating microorganisms from entering or escaping) would say that there is NO chance of a virus release, but only that the chance is very, very low. Well, that likelihood can be as low as the sponsors of the NBAF here would like to make it, because that release only has to happen once, and it is as likely to happen during the first hour that H&M virus is used, as during the lab’s 25th year in the future. The effects in both cases will be the same: the required euthanization of all livestock within a very large radius around KSU and the already predictable responses by Japan and other markets for Kansas beef.

The scientific logic supporting the location of an NBAF here therefore is deeply flawed. The NBAF could easily be located at any of a variety of sites along (or off) the East coast, where prevailing winds would blow any virus released out to sea. That was (and still is) the logic for choosing Plum Island. Such a site could be as easily defended from terrorists as any lab here. At many remote coastal sites few people would routinely travel close to the lab, in remarkably sharp contrast to the KSU site sitting amazingly only a few hundred yards away from parking lots full of football fans. Thus, to locate the NBAF here, in the middle of cattle country, is like building a brand-new, very safe fireworks factory right in the middle of a functioning oil refinery, unfortunately also an analogy that could equally well be applied to the logic of building an oil pipeline over the Ogallala High Plains/Great Plains Aquifer that supplies drinking and agricultural water to 8 states from South Dakota to Texas.

The scientific logic underlying both the KSU-NBAF and the pipeline projects is that the risk of a single release of H&M virus or of a large oil spill is very, very low. The flaw in that logic, however, is the lack of consideration given to the already predictable, instant, long-term consequences of either such incident, accidental or willfully purposeful. Yes, it would only take one malicious person in the NBAF, or standing next to that pipeline, to perform one bad action and the future of the Mid-west would be changed in a heartbeat.

Instead, let’s look for other, less dangerous ways to create jobs and funding for Kansas than thinking that the laws of scientific logic do not apply here, or that they can be re-defined.

Sincerely, Gary W. Conrad 610 Fairchild Terrace Manhattan, KS 66502

Note: although I am a Professor of Biology at KSU, I am writing this letter as simply a private citizen. I am NOT a spokesperson for KSU in this matter. Thank you.

 

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NRC Meets at KSU to Review DHS Risk Assessment

Posted by tmanney on January 31, 2012

Members of the National Research Council held a public hearing on the risks associated with National Bio- and Agro-Defense Facility Friday morning in Manhattan, where the U.S. Department of Homeland Security is building the $650 million lab near Kansas State University. As part of the project’s funding, Congress has required the National Research Council to conduct a risk assessment on the lab. An initial risk report was released in 2010. That report raised questions that led to further review of the lab and the plans for security measures to protect livestock and humans if pathogens are released. The NRC held an information gathering hearing prior to the release of the DHS revised risk assessment.

The first hour of the meeting was a question and answer session between four members of the NRC committee and selected members of the KSU Veterinary Medicine faculty and administration. The second hour was public comment.

Following are written comments submitted to the NRC committee elaborating on comments

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Major Problems Have Not Been Addressed

Posted by tmanney on January 31, 2012

1/30/2012

From:

       Bill Dorsett

       1715 Leavenworth

       Manhattan, KS 66502

       785/539-1956

To:

            Peggy Tsai, Program Officer                                                                                                                        

            Board on Agriculture & Natural Resources

            National Academies of Sciences

 RE: NBAF, Public Comments

The goal of the National Academies of Sciences in Friday’s NBAF hearing was to judge whether the science underlying the biolabs’s design is “adequate” and “valid.” But several major issues brought up by the previous NRC committee will remain a problem no matter how many risk assessments are done: 1. the fact that the DHS SSRA gives incomplete thought to pathogens other than FMD, 2. this is by definition a large animal facility. 3. how to build and maintain a safe lab on a finite but unpredictable budget (“Value Engineering”).

  1. Avian flu H5N1 has proven hugely lethal particularly to birds raised for food, and penned in close quarters. So there is every reason to believe that it will be added to the select pathogens studied at NBAF. This particular strain of flu virus is also among the deadliest to humans.

To put this in context, the notorious 1918 flu pandemic (originating at Ft Riley) killed 40 million to 50 million people worldwide but was lethal to only about 2% of those infected.  This one kills close to 60%. Until last month, scientists haven’t been overly concerned because H5N1 hasn’t been easily transmitted to or between humans.

Probably even at the time of the most recent Homeland Security design revisions, Dutch experiments hadn’t yet shown that a new variation of H5N1 can be readily transmitted through the air, from mammal to mammal. This Dutch experiment produced calls from the bio-security community for international oversight of potentially dangerous experiments.

But experience tells us that DHS would be unresponsive to international concerns. In 2002, the US admitted that against WHO convention, it holds viruses that are combinations of smallpox virus with animal poxviruses such as rabbitpox and cowpox. WHO quickly called for their immediate destruction; but the US has refused and now says that it wishes to increase experimentation with the hybrid viruses. The US justification was that its national security demanded more research on defenses against smallpox used as a biological weapon. Given this precedence, why should we believe DHS will be forthcoming to international concern, much less be responsive to any local oversight committee.

 In spite of KSU’s insistence that layers of veterinary surveillance will catch exotic diseases, one has to doubt that local vets and certainly not students will have full information of what pathogens are being studied in NBAF, and how they are being genetically manipulated leading to totally different symptoms. Why would we expect them to know symptoms of diseases they are not told about?

Even then, the probability of misdiagnosis of unfamiliar diseases is high. Ft Detrick’s own medical staff diagnosed one of its researches as having flu when in reality it was tularemia.

So how do DHS plans “adequately and validly” protect the public, or the local infrastructure prepare, when the agencies running the lab have a history of secrecy?

  1. Proponents’ comparison the CDC in the middle of Atlanta with NBAF is clearly for non-scientific public consumption. In Atlanta, no researchers climb into the isolation cabinet with the infected steer. The sheer volume of ventilation air, feed and waste won’t change regardless of the number of risk assessments.
  1. Value Engineering   In these years of lean budgets, we can assume that the lab’s design is very mission oriented…no frills.  Yet in the last National Academies’ critique, an overarching concern was “Value Engineering. For example, given the destruction from F5 tornados on Joplin and Greensburg, the lab design is being revised from an F2 to an F3 tornado*. In response to the expense of additional concrete and rebar, will Homeland Security settle for i.e. software controls that are more vulnerable to something comparable to the Stuxnet computer worm which made Iran’s nuclear centrifuges spin out of control?

And just as critical as the construction phase, how can anyone in the realm of science project future congressional budget cuts to the lab’s upkeep? One of the Pirbright Laboratory releases is thought to have been caused by tree roots growing into a sewage line….deferred maintenance caused by a tighter budget.  That concern goes double for subcontracting to management corporations. It is predictable, for example, that periods of quarantine following extended or especially hazardous work shifts would reduce profitability.

Each of these issues shows the futility an agency faces when it tries to engineer order on human unpredictability. The NRC is being asked to sign off on the “adequacy” and “validity” of hard science over “soft.” The cost of failure could be unimaginable. It would be ironic if Ft Riley/Manhattan hosts its second global flu pandemic.

*We are not as concerned about structural destruction of the lab from a tornado, as we are the more subtle effects of tremendous overpressure changes on HEPA filters, door seals and internal air balances.

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Another Look at the Tornado Risk

Posted by tmanney on January 31, 2012

 

 

COMMENTS TO NRC COMMITTEE CONCERNING NBAF SSRI

By Thomas R. Manney

Professor Emeritus, Department of Physics and Division of Biology

Kansas State University

January 30, 2012

 

            My comments concern an aspect of the risk that pathogens will be released by a tornado. When a strong tornado passes near a structure, two forces must be considered.  First, the kinetic energy of the winds can produce catastrophic damage to inadequate structures.  Second, the vortex of a tornado produces a sudden, local, severe drop in the atmospheric pressure. The pressure drop may contribute to structural damage, but it may well have additional consequences when the objective is to keep the contents of the building, especially microorganisms, from escaping.

 

In the SSRA , most of the discussion of risks posed by tornados has focused on the potential for structural failure or collapse. But I have found no consideration of the possibility that a sudden drop in atmospheric pressure could contribute to the release of pathogens from negative pressure containment compartments.

 

There are relatively few research papers reporting direct measurements of ground-level pressures near tornados.  An apparently definitive paper is “Pressure at the ground in a large tornado” (W. P. Winn, S. J Hunyady, and G. D Aulich Journal Of Geophysical Research, 104, 22,067-22,082, 1999).  They measured pressures near an F4 tornado in Allison Texas in 1995. They reported, “The instrument closest to the tornado recorded a pressure drop of about 55 mbar (hPa) as the tornado approached and a rise of about 60 mbar (hPa) as the tornado receded.”

 

 Another group has summarized measurements near 24 tornados with a range of pressure deficits from 5 hPa to 194 hPa,(“Near-Ground Pressure and Wind Measurements in Tornados” by Christopher D. Karstens, et. al., in Monthly  Weather Review, 138, 2570-2588, 2010).

 

            A fundamental principal of containing microorganisms is to maintain them in a sealed chamber that is kept at a negative pressure.  The pressure in the chamber must be kept below the pressure outside the chamber. A typical value for this negative pressure in a Class III biological safety cabinet is quoted as at least 0.5 inches of water. In units of inches of water, a pressure of one atm is about 400 inches, so the pressure deficit measured near the Allison, TX tornado would have been about 24 inches.  The magnitude of this pressure drop is about 50 times the small negative pressure difference commonly maintained between  a Class III containment chamber and its surroundings.

 

            A Class III biological safety cabinet, for example, is a closed, gas-tight enclosure fitted with arm-length rubber gloves.  All supply air is filtered through HEPA filters and exhaust air is filtered through two HEPA filters in series. An exhaust blower maintains negative pressure.  Although the normal fluctuations of atmospheric pressure are themselves greater than this negative pressure difference, the fluctuations are relatively gradual so the exhaust blower can easily maintain the differential. The same reasoning would apply to larger containment spaces used for handling live animals, such as cattle, in BL-3 Ag facilities.

 

            In the event of a tornado, however, the pressure drop is sudden.  The question then is whether the system can maintain the negative internal pressure in the event of a large, sudden depression? The seals around doors in large chambers have been a historical weakness. Have they been designed to handle such a transient event (and if so, can that be verified)?

 

            In conclusion, the apparent potential for a strong tornado to over-power the containment door seals, thereby releasing pathogens into the tornado, is a serious consideration that I have not seen discussed in the SSRA.

 

 

 

 

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Letter to Livestock Producers

Posted by tmanney on February 1, 2011

We are sending the following letter to livestock producers in Kansas and surrounding states to inform them of the risk to their livelihood that is posed by the NBAF, in Kansas or anywhere else on the U. S. Mainland. We are urging them to contact their legislators and tell them of their real concern about having Foot and Mouth Desease Research conducted in the middle of cattle and other livestock production.

To: Livestock Producers

Re: National Bio- and Agro-Defense Facility (NBAF): new threat to U.S. livestock exports.

The Department of Homeland Security is ready to build a huge laboratory to study diseases that might threaten our livestock industry if they were imported. The most contagious would be Foot-and-Mouth-Disease (FMD).

During the site selection, Congress asked the General Accountability Office (GAO) to study the risks of permitting FMD research on mainland United States. The GAO released its conclusions in 2008 with the title “HIGH-CONTAINMENT BIOSAFETY LABORATORIES: DHS Lacks Evidence to Conclude That Foot-and-Mouth Disease Research Can Be Done Safely on the U.S. Mainland”. The location selected by the Department of Homeland Security (DHS) for this one-of-a-kind lab is Manhattan, KS.

Alarmed by the GAO’s report, members of the Appropriations Committee asked Homeland Security to do a more thorough study of the risks of building this facility in Manhattan –  before releasing money to build the lab. And they asked a committee of experts appointed by the National Academy of Sciences to review the methods used by DHS in this evaluation.  Last November, the Academy committee released its review with some conclusions which should concern all livestock operators.

  • DHS Assumptions are over-optimistic partly because of huge differences between working under a sleeved isolation box, and working in direct contact with large animals and their excretions.
  • In trying to meet a budget, safety shortcuts are being made in the lab’s designs that increase the probability of an FMD release. Examples are the cutting of redundant HEPA filters (Pg 52-53), or building the lab to withstand no more than an F2 tornado (Pg 33). Manhattan experienced an F4 tornado in 2008 which damaged buildings next to the NBAF site.  Furthermore, long term maintenance is critical. (Weathered gaskets and air filters will have to be replaced through all future administrations and budgets…without fail.)
  • KSU Vet Medicine is next door and livestock research feedlots are less than two miles away. The NBAF site is directly cattycorner from football overflow parking. Large crowds leaving KSU events or games could very well carry the virus particles in dust or mud home. (Pg 21).
  • Based on the DHS estimates, the reviewers calculated a cumulative risk of an outbreak as being a coin toss within 30 years of the lab’s completion and a 70% probability by the end of its life (Pg 30).  This is not a “low probability” event as presented by Homeland Security. Calculating the cumulative risk this way is often used by institutions in locating nuclear installations or by research scientists to determine probability of infectious disease outbreaks.
  • Detection and destruction of infected herds will not be as rapid as DHS expects, so the duration and spread of an infection is likely to be much more extensive (Pg 38).

Probably only those with disposed of livestock will be compensated and then by whom?  Faced with billions of dollars in losses, will your insurance company consider this an “act of God”?   Operators of uninfected ranches and feedlots in every state will suffer a loss of both American and export markets with the overall toll projected to be in the $9 to 50 billion range (Pg 58).

Enclosed are the executive summaries of both the GAO and the National Academy of Sciences reports and a CD with both full reports, a list and contact information of the House and Senate Appropriation Subcommittee members.  If you believe that this could hurt your investments, look at the portions of the full report that apply to you.

Congress has yet to appropriate the actual construction money, but that could be done within the next two months.  This time period will be critical in determining whether the lab will be built. As area ranchers, scientists and Manhattan residents we ask that you:

1.   Have your family, friends in the business, and livestock organizations, call or email the members of the House and Senate Appropriations Committees to NOT release the construction funds.  Join us in calling for an injunction against further construction until the committee formed by the National Academies of Sciences amends their study to confirm that a BSL-3Ag and BSL-4 large animal laboratory can be safely placed at the Manhattan, KS site.  In the previous study, the committee was instructed by Congress not to include this in their scope of study.  Copy, cut, paste any and all of our material.

2.   Ask for repeal of the previous legislative language (inserted in the Senate) that requires DHS to sell Plum Island Animal Disease Center in the event another site is chosen for NBAF.  The Plum Island sale language forces an unnecessary urgency and requires the government to sell the island, liquidate its existing lab and apply all proceeds to NBAF. The Plum Island sale language creates an artificial timeline and makes this a “done deal.”

While this research may be important, it must only be done in the proper perspective of its risks.  We just ask that this it be kept on an island where the prevailing winds blow infections out to sea instead of over surrounding states …in Kansas, that’s from any direction the wind blows.  A release of FMD virus on an island will not have a chance to infect nearby cattle headed for sale barns and feed lots before it is even detected.

Proponents of placing NBAF in Kansas responded to the NAS evaluation by saying that this facility is only in the planning stage, and that many of the National Academy of Sciences committee’s concerns are already being addressed. However the fundamental concerns are inherent in today’s economic times and its proposed location on the edge of a university town in the middle of cattle country. Budget deficits in Washington are out of Homeland Security’s control, and will require such cuts as the Academy fears. KSU will continue having football games across from the lab and draw crowds to University events.  And they will say that there is already a FMD vaccine – they won’t say for only three of the 77 different subtypes.

Don’t take our word for it. Look at the reports. We have nothing to gain personally from opposing this.  At least for the short term, our homes and land will lose value if the lab is built elsewhere. We know that in portions of our community, we will be ostracized for working to end a billion dollar gold rush. However, after a leak we won’t be able to give our property away.

NoNBAF in Kansas

Real BioSecurity for the Heartland

For more information go to:   http://nonbaf.wordpress.com/

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NBAF Status Report

Posted by tmanney on February 1, 2011

In 2018 Manhattan will become a different kind of place if the U. S. Dept. of Homeland Security (DHS) and KSU have their way.  It will become the world-famous home of a major biodefense germ laboratory, the NBAF.   It is being built next to the KSU Biosafety Research Institute (BRI) and veterinary medicine, across from the football stadium, and less than a mile of the livestock area of campus.

NBAF will replace the Plum Island Animal Disease Center, on an island just off of Long Island, New York. This is the only place in the U. S. where Foot-and-Mouth Disease can be studied. The 9/11 attacks and the anthrax letters triggered a seemingly hysterical escalation of the domestic biodefense effort.  The expected $450 million lab propelled a contentious and highly politicized nation-wide competition to be the site for NBAF. The new facility would not only bring the risk for studying Foot and Mouth Disease onto the mainland, but would study agents that can infect both animals and humans and for which there is no cure or vaccine. These require the highest level of biosafety containment.

For the proponents it is all about economic development and fighting biological terrorism. The imposing list of proponents includes the U.S. DHS, K-State, and the Kansas Bioscience Authority, the entire Kansas congressional delegation, the Manhattan Chamber of Commerce, The Manhattan Mercury, the Kansas Farm Bureau, the Kansas Livestock Association, and the Manhattan City Commission.

For most of the opponents, it is about public safety. The principal critics are the Governmental Accountability Office (GAO), the National Academy of Sciences committee, a variety of national livestock organizations, Kansas Cattlemen’s Association and a loosely knit group of Manhattan concerned citizens and ranchers calling themselves No NBAF in Kansas

Homeland Security selected Manhattan as the site over the warning of the GAO, who reported to congress that DHS lacks evidence to conclude that Foot-and-Mouth Disease Research can be done safely on the U.S. mainland. This alarmed members of the House and Senate Appropriations Committee who called for DHS to complete a Site-Specific Risk Assessment (SSRA) to address GAO’s concerns, with the condition that DHS’ methodology would be reviewed by the National Academy of Sciences (NAS/NRC). However NAS was specifically told neither do an independent safety evaluation nor judge Manhattan’s selection.

Their November report concluded that there was a 70% chance that Foot-and-Mouth Disease would be accidentally released from the site during the facility’s lifespan. Millions of livestock would be slaughtered, as is happening now in Korea and U.S. beef exports would be embargoed worldwide. It would cost the nation between $9 and $50 billion.

The proponents tried to discredit the reports by characterizing this threat as “extremely low.” Sen. Brownback attached a $40 million earmark to the spending bill that would begin work on the Manhattan site. The earmark was cut in the final days of the 2010 session.

The National Academy acknowledged that the Plum Island facility is old and needs repair, but also that “further risk analysis” was needed to validate the site in Manhattan. The NAS committee concludes the only thing they were mandated to say, “Ultimately, policy makers will need to decide whether the risks of constructing the lab in Manhattan, Kansas, are acceptable.”

The No NBAF in Kansas is trying to rally an appeal to members of the House and Senate Appropriations Committees to not approve the funds, and to repeal language inserted by the Senate requiring DHS to sell Plum Island. This creates an artificial timeline and makes this a “done deal.”

Recommended Reading:

Kenneth King, Germs Gone Wild, 2010 (Pegasus Books, LLC)

Michael Christopher Carroll, Lab 257, 2004 (Harper Books)

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Contacting Influential Legislators

Posted by tmanney on February 1, 2011

The following link goes to a list of the Representatives and Senators who will most likely decide whether or not the construction funds for NBAF are appropriated. It is difficult to communicate with any except those in your own district, especially by email, so it is important to look for ones who are.  Postal mail is very slow because it is screened for anthrax and other suspicious materials. It is worth while to try FAX numbers.

Congressional Contacts – NBAF

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The NAS Report on NBAF is a Game Changer

Posted by tmanney on December 4, 2010

When the the Department of Homeland Security (DHS) selected Manhattan as the site for the NBAF there was little this group could do until the funding process worked its way through Congress.  Because of the concerns raised by the Government Accountability Office (GAO) Congress instructed DHS to complete a “site-specific biosafety and biosecurity risk assessment (SSRA)”.  They also directed the National Research Council to conduct an independent evaluation of this SSRA to determine its adequacy and validity.  Congress would not release construction funds until these were completed and evaluated. We had to wait for the outcome of these even though the DHS/KSU/Kansas Bioscience Authority (KBA) started site preparation on the KSU campus using Kansas State and local funding.  These documents were released last month.  But Congress has not appropriated any funds for construction.  This can still be stopped.

The NRC evaluation found many serious faults in the DHS plans that call into question the decision to build the NBAF in Manhattan.  The composition of the NRC commission included leading experts in most, if not all, of the fields relevant to this incredibly complicated project.  Their 11 findings echoed the objections opponents to the NBAF (including us) had raised, which were based on the concerns raised by the GAO more than two years ago.  These findings reinforce our resolve that it is simply unacceptable for this facility to be built on the KSU campus in Manhattan. The findings concerning the risk of release of the Foot and Mouth Disease virus (FMDv) further reinforce our resolve that it is unacceptable to study this disease in large animals on the mainland of the United States.

To address these issues and work toward the goal of persuading Congress to refuse to fund this project, we have regrouped under a new name, but with the same objectives.  We will now identify our goal to be Biosecurity For the Heartland. We will soon move these efforts to a new web site under that name.  The only weapon we have at our disposal is information.  We can shine light on the facts that are a matter of public record and on the efforts by the proponents of this project to obscure those facts that challenge the project’s safety.

Because of the urgency of preventing the funding of this project, we will focus our efforts on the members of Congress who will be making this decision:  the members of the House and Senate Appropriation Committees, starting with the members of those committees who serve on their Homeland Security subcommittees.  To get our message to these members of Congress we will do our best to recruit those people who have the most to lose in the event of an FMD catastrophe:  the livestock growers and the organizations that represent them.  But Foot and Mouth Disease isn’t the only threat from this facility.  This germ lab is designed to study the most deadly diseases that infect both animals and people.  These are diseases that are deadly to people and for which there is no known vaccine or cure.  Every person who lives in the long shadow of this facility must understand  the risks.

Biosecurity For the Heartland is a coalition  of area residents who want to stop this madness by honest, rational information sharing and discourse.  None of us have anything to gain by the defeat of NBAF except a safer place to live and raise our families.

 

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