No NBAF in Kansas

Real Biosecurity for the Heartland

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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. ( “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

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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

Posted in "site-specific biosafety and biosecurity risk assessment (SSRA), Uncategorized | Tagged: , , | Comments Off on NBAF Risk Assessment is a Theory With Limited Predictive Value

Decision pending?

Posted by Dale on November 23, 2008

Things have been quiet on the NBAF front of late. Other than a brief kerfuffle over Texas’ attempt to sweeten the deal by throwing more state money on the table, it’s really been a waiting game for the most part. As everyone likely knows by now, the final environmental impact statement should appear soon with a site recommendation. Thirty days after its appearance, the Department of Homeland Security, specifically Jay Cohen, can issue a final site selection.

As The Mercury helpfully pointed out the other day, this can only happen if the EIS is issued by December 21st, since Jay Cohen and the rest of the Bush appointees are out of a job on January 20th. What this means is that there will certainly be a pell mell rush to get the EIS out (meaning we’ll likely see as many glaring errors as we saw in the draft EIS) so that Cohen can make his selection.

Is it just me, or does this all seem simply ceremonial at this point? Can anyone really imagine that this monstrosity will move forward under an Obama administration? The whole war on terror, as we now know, is largely a ploy by the Bush administration to consolidate its power and enrich its groupies. Anyone who feels safer today than he or she did on September 10, 2001 is really living under the delusion that military might, applied indiscriminately, equals security. What we most certainly are today compared to then is a whole lot poorer as a nation.

Last I read, we’re something like $10 trillion in debt, are issuing checks to bank and auto dealers like it’s grand fun, and yet no one really seems to have a plan for stabilizing the economy other than some tired trickle-down shenanigans. We’ve also spent hundreds of billions of dollars on the actions in Afghanistan and Iraq, something that has been consistently downplayed, not least in the recent election. These expenses will likely cripple our government for years to come. In that fiscal climate, coupled with the fact that someone was just elected president who is not beholden (at least not entirely) to the military industrial complex, do we seriously think that the federal government is going to drop what would likely end up being billions to build a lab of this nature, anywhere? Even if they wanted to proceed, the environmental lawsuits that will surely spring up regardless of the site selected will deter even the most convinced or co-opted government bureaucrat.

What amazes and truly disappoints me is that these financial considerations will likely be the downfall of the NBAF. That’s a comforting thought, but it remains puzzling to me why anyone thinks it’s a good idea to build such facilities in populated areas, and in the case of Manhattan, within a stone’s throw of at least three existing or planned daycare facilities. That would seem to require a margin of error of absolute zero, something even the most pro-NBAF scientists cannot claim to be a realizable goal.

Posted in >Department of Homeland Security (DHS), >Economic Impact | Tagged: , , , , | 1 Comment »

National Coalition Joined in Statement on Biodefense Program

Posted by tmanney on September 17, 2008

PRESS RELEASE – For immediate release

No NBAF in Kansas

P.O. Box 703
Manhattan, KS 66505-0703

September 18, 2008


CONTACT:             Tom Manney, Chair

                             Tel. 785-537-0624            

 National Coalition Issues Statement on Biodefense Program

Concerned citizen groups in 7 states, affected by 8 potential or existing federally-funded high containment “biodefense” labs have issued a joint statement expressing specific, local health, safety and environmental concerns about these labs existing in their midst.   Two current and one former candidate NBAF sites, including Manhattan, Kansas are among them.  The statement is being distributed to appropriate congressional oversight committees, and national and local media in the represented areas. 


Statement on the U.S. Biodefense Program

from Communities Living in its Shadow 

We, the undersigned, face the reality or prospect of federally-funded high containment “biodefense” labs being built and operated in our communities.  We all have specific, local health, safety and environmental concerns about these labs existing in our midst.  We represent citizen groups from around the U.S., united in our belief that the massive proliferation of “biodefense” laboratories creates a significant threat not just to our communities, but also to our nation, and to our world.  We join Biological Weapons Convention non-proliferation experts in concluding that we risk creating a biowarfare arms race with those who do not trust and cannot verify our intentions.  The proliferation of these labs makes us all less safe.

Since the August 2008 revelations about the 2001 anthrax letters originating from within the premier U.S. “biodefense” lab, it has become tragically clear that Congress must move quickly to investigate the nation’s “biodefense” programs. 

We have many concerns about the proliferation of bio-safety level 3 and 4 laboratories in federal complexes, and in the hundreds of poorly regulated academic and private sector laboratories around the country.  

·      In each of our communities, we have found that environmental impacts and hazards associated with these labs have not been analyzed with thoroughness, clarity and scientific rigor.  It is not possible to mitigate unacknowledged risks.  

·      Our experience is that State and local governments have not been well integrated into lab planning and operations.  

·      We are concerned about the threats associated with genetically modified pathogens and dual-use research.   

·      We are most concerned about supposedly low-probability” but “high-consequence” accidents that could result in a public health disaster. 

·      Now we also know that the possibility of internal sabotage is quite real.  We have been told officially that both the “weaponized” anthrax and the perpetrator of the only bio-terror attack in our history came from within the U.S. “biodefense” program.  

·      We are sobered by the fact that since the anthrax letter attacks, the number of workers in these labs has grown from a small number to over 16,000;  laboratory space has grown tenfold.   

·      Numerous laboratory accidents have been reported.  It is plain that many others go unreported, as demonstrated by the unreported accidents discovered by non-governmental watchdog groups.  

·      It has become clear that laboratory regulation and oversight are poor.   

·      Transparency has been lacking.  

·      The GAO and others, such as the Sunshine Project, report that safety programs and protocols are inadequate and have not been followed with consistency and rigor.  

Since 2001, “biodefense” funding has provided a $57 billion economic boon, much of it for the private sector.  “Biodefense” programs are spread among many federal departments, but are frequently duplicative and poorly coordinated.  We have seen no evidence of an integrated federal policy, still less one openly debated by Congress.   

Congress must investigate current research and development priorities, funding levels and research requirements in relation to verifiable threats to human and livestock health.   Our country needs a fact-based assessment of biological threats, both natural and man-made.  

 In 2005, more than 750 scientists, including Nobel Prize-winners, decried the diversion of funds to “biodefense” programs away from vital and pressing human health research of broad applicability.  

 We are aware that intense debate is taking place within the scientific community about whether or not much of the new “biodefense” research is relevant to or would be effective in protecting the population against a biological attack.  At the same time, funding has been cut for local preparedness against potential natural or lab-generated outbreaks.   These issues are equally present in the debates taking place about the enormous high-containment agricultural research laboratory complexes proposed for some of our communities. 

 The size and research agenda of the U.S. “biodefense” program has become out of control in the wake of the 2001 anthrax letters.  Who decided it was an acceptable risk to genetically re-create and work with the formerly extinct 1918 flu virus, no matter how interesting that research may be?  There are far too many comparable examples.  

We need a national moratorium on “biodefense” research and, simultaneously, a serious and transparent reevaluation of the big picture.  We need a great many more answers before our government pours yet more money into these programs and creates new public health risks and international strain.

Consistent with standard procedures for other federal science programs that pose potential threats to health and safety, we call upon our elected representatives to:

 ·      Conduct a thorough independent investigation of the executive policies that have driven the unprecedented expansion of “biodefense” research and development since 2001; and 

·      Call  an immediate halt to development of new “biodefense” facilities and an operational stand-down of existing programs until the many serious questions have been resolved,  including those related to:

       public safety, 

       biosafety and biosurety compliance,

       laboratory regulation,

       research focus,

       select agent use and control, 

       dual-use research,

       a right-sized program and

       appropriate locations for high containment laboratories.  

Signed September 17, 2008:





Boston Coalition to Stop the BioTerror Lab

Boston University, NEIDL;  BSL-4 and BSL-3 Labs (NIH)

Boston, MA


Cummings School of Veterinary Medicine, Tufts University, Grafton, MA

BSL-3 labs, BSL-4 ready


Frederick Citizens for Bio-lab Safety

National Interagency Biodefense Campus, Fort Detrick;  BSL-4 and BSL-3 labs (USAMRIID, DHS, NIH)  Frederick, MD


Granville Non-Violent Action Team (GNAT)


NBAF, proposed site at Butner, North Carolina; BSL-4 and BSL-3 labs (DHS)

No NBAF in Kansas

NBAF, proposed site at Manhattan, Kansas, at Kansas State University; BSL-4 and BSL-3 labs (DHS)

Mid-Missouri Branch of WILPF,  (No NABAF in Columbia, MO)

University of MO, BSL-3 lab;  and formerly proposed site for NBAF, Columbia, MO  (NIH)

Tri-Valley Cares

BSL-3 facility at Lawrence Livermore National Laboratory, Livermore, CA (DHS)

Labwatch – Seattle, WA


WWAMI Regional Center of Excellence for Biodefense and Emerging Infectious Disease, Seattle, Washington, BSL-3 labs (NIH)


Posted in >Accidents, >Accountability, >National Bio and Agro Defense Facility (NBAF), >Oversight, >Proliferation, >Risks, >Transparency, Do Something! | Tagged: , , | 2 Comments »

Quotation of the day ….

Posted by tmanney on August 18, 2008

The following is taken from Final Selection Memorandum For Site Selection for the Second Round Potential Sites for the National Bio and Agro-defense Facility (NBAF) from the Science and Technology Directorate of the DHS.  It refers to the evaluation of the   Heartland BioAgro Consortium which submitted the local proposal.

“Additionally, the consortium demonstrated a continuing commitment to NBAF and has garnered and maintained significant community acceptance and public support for the program. Support is strong and broad from political, business, agricultural, and academic stakeholders. The coherent and persistent messaging and continuous outreach from the consortium on the benefits of placing the NBAF at this location continues to foster public support. There is no known public opposition to locating the NBAF at this site.” (Emphasis added).

Posted in >Department of Homeland Security (DHS), >National Bio and Agro Defense Facility (NBAF), Do Something! | Tagged: , | 1 Comment »

What can you do to stop this?

Posted by tmanney on August 16, 2008

What can you do to stop the Department of Homeland Security from building a dangerous, secret, deadly germ lab in the heartland?

Get informed.

Don’t rely on the mainstream press for your information. Most of the information that has been published comes from people who have something to gain from having the lab build here. The blogs on this site will help you find independent sources of information. You can also share information, and have your own concerns heard. See what is in the Environmental Impact Study (EIS) prepared by the Department of Homeland Security
(DHS). Read why the Government Accountability Office testified to congress thatDHS Lacks Evidence to Conclude That Foot-and-Mouth Disease Research Can Be Done Safely on the U.S. Mainland.”

Speak up.

The Department of Homeland Security is required to record your comments until August 25, 2008.

Toll-Free Voice Mail: 1-866-501-NBAF (6223)

Toll-Free Fax: 1-866-508-NBAF (6223)

Online: e-mail

U.S. Mail: U.S. Department of Homeland Security; Science and Technology Directorate; James V. Johnson; Mail Stop #2100; 245 Murray Lane, SW; Building 410; Washington, DC 20528

Tell your legislators.

The Department of Homeland Security cannot build anything unless Congress appropriates the money. Click on Government Contacts in the menu bar above to learn how to contact them. Use email, phone, or FAX because postal mail to legislators is still experiencing long delays because of the 2001anthrax attacks.

Meet with your neighbors.

The No NBAF in Kansas protest group will hold a public meeting:

Tuesday, August 19, 2008

Riley County Senior Service Center

412 Leavenworth

Manhattan, KS 66502

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Letter to The Editor of The High Plains Journal

Posted by nonbafks on August 12, 2008

To the Editor-Holly Martin:

            We must continue our protest of this NBAF facility the DHS is trying to get into Manhattan, KS. , where they would introduce F.M.D. and some of the most dangerous pathogens in the world.   These pathogens could wreck our livestock industry, not only when a release occurred, but for years to come.  The September (latest)  issue of the Farm Journal conducted a mock outbreak of F.M.D. and the chaos that results.  Everyone should read this article.

            The G.A.O. report of May 2008, states unequivocally that the DHS has not demonstrated that it would be safe to study F.M.D. on the U.S. mainland.  The proponents will tell you how safe these labs are, but there is no way to guarantee that there will never be human error.  A good example of this is the anthrax case where Bruce Ivins took the pathogens out of the lab and dispersed it killing 5 people and sickening others. 

            This lab should not be placed on the mainland, but should be built on Plum Island, which would offer better protection due to its isolation, and due also to the fact that it is not in the middle of a large concentration of livestock.  I am in agreement that this research is important, but not in the heart of Kansas, which is one of the top beef producing states in the United States.

            There is an organization that is strongly opposing this lab.  This is called “NO NBAF IN KANSAS”.  The blog site is

            Communications may be sent to P.O. Box 703 Manhattan, KS 66505.  Contributions are welcomed and needed.  The comment period ends on August 25.  Calling the hotline number 1-866-501-NBAF (6223) is very important and must be done soon. 





785-556-6885 –CELL

785-776-6083 -HOME

Posted in >Economic Impact, >National Bio and Agro Defense Facility (NBAF), Do Something! | Tagged: , , | Comments Off on Letter to The Editor of The High Plains Journal

Make Comments on the Draft EIS

Posted by nonbafks on August 9, 2008

The public comment period for the draft Environmental Impact Statement for the National Bio- and Agrodefense Facility closes on August 25, 2008. Comments can be made by many means, details here.

It probably goes without saying that it might be useful to glance at the draft EIS before making comments. There’s a link to it in the righthand column of this site. It’s terribly long, but one can fairly easily locate the relevant sections for Manhattan, which offer plenty of material for substantive comments about underestimation of risk.

Posted in >Department of Homeland Security (DHS), >Draft Environmental Impact Statement (EIS), Do Something! | Tagged: , , | 1 Comment »