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DUAL USE RESEARCH OF CONCERN Environment, Health & Safety University of North Carolina @ Chapel Hill

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DUAL USE RESEARCH

OF CONCERN

Environment, Health & Safety

University of North Carolina @ Chapel Hill

Overview – The Fink Report

2003 - The National Research Council’s “Committee on Research

Standards & Practices to Prevent the Destructive Application of

Biotechnology” published a report entitled “Biotechnology

Research in An Age of Terrorism: Confronting The Dual Use

Dilemma”. (Fink Report)

The Committee recommended the creation of the National Science

Advisory Board for Biosecurity (NSABB) to educate scientists &

advise the government on the oversight of “dual use” research.

National Science Advisory Board

for Biosecurity (NSABB)

The NSABB provides advice, guidance, and leadership

regarding biosecurity oversight of dual use research to

all Federal departments and agencies with an interest in

life sciences research (including Institutional Biosafety

Committees-IBCs).

Dual Use Research vs.

Dual Use Research of Concern

“Dual Use Research” is research that has the potential

to be misused for nefarious purposes.

Almost all life science research has some potential for

misuse and therefore can be considered to be Dual

Use Research.

The NSABB thus defined a special category: “Dual Use

Research of Concern”, or DURC

that warrants particular attention.

Dual Use Research of Concern

(DURC)

* “The National Science Advisory Board for Biosecurity

(NSABB) has defined Dual Use Research of Concern

(DURC) as: “research that, based on current understanding,

can be reasonably anticipated to provide knowledge,

products, or technologies that could be directly misapplied

by others to pose a threat to public health and safety,

agricultural crops and other plants, animals, the

environment or materiel”.

*NSABB 2004

2012 U.S. Government Policy on

Dual Use Research of Concern

Partly in response to public concerns over experiments

aimed at broadening the host range of highly

pathogenic avian influenza to mammals, the U.S.

Government issued a policy on oversight of dual use

research of concern (DURC) in March 2012. This policy

requires funding agencies to review ongoing research

for DURC and to establish criteria for the management

of any research that is identified as DURC.

2012 U.S. Government Policy on

Dual Use Research of Concern

Although all life sciences research has the potential to

meet NSABB’s definition of DURC, the 2012 U.S.

Government policy on DURC applies only to research

with certain infectious agents and toxins that are utilized

in experiments with potential to cause seven

experimental effects.

In the future, the policy’s scope may be broadened.

2014 Policy on Institutional Oversight of

Dual Use Research of Concern

In September of 2014 the U.S. Government issued an

additional policy on institutional oversight of dual use

research.

The 2014 policy goes into effect on September 25, 2015

and provides a framework for local oversight of life

sciences research.

The UNC policy on Dual Use Research of Concern ensures

compliance with the 2012 and 2014 federal policies.

Scope of the DURC Policies:

Agents or Toxins

Under the 2012 and 2014 policies, DURC review will focus on research that involves

one or more of the following select agents or toxins:

Avian influenza virus (highly

pathogenic)

Bacillus anthracis

Botulinum neurotoxin

Burkholderia mallei

Burkholderia pseudomallei

Ebola virus

Foot-and-mouth disease virus

Francisella tularensis

Marburg virus

Reconstructed 1918 Influenza

virus

Rinderpest virus

Toxin-producing strains of

Clostridium botulinium

Variola major virus

Variola minor virus

Yersinia pestis

Scope of the DURC Policies:

Seven Experiments of ConcernThe NSABB identified 7 categories of experiments that pose DURC potential. The scope of the 2012

and 2014 DURC policies are limited to the 15 select agents listed in the previous slide when utilized in

experiments that may be associated with any of the following experimental effects. Such experiments

are not prohibited but their risks vs. benefits, and how to communicate the results, must be approved

before starting the research.

1. Enhances the harmful consequences of an agent or toxin.

Example: Modify an agent’s genome to express biological toxins it previously lacked.

2. Disrupts the immunity or the effectiveness of an immunization without clinical and/or agricultural

justification.

Example: Information on the insertion of an immunosuppressive cytokine into a viral genome to render the antiviral

immune response less effective.

3. Confers to the agent or toxin resistance to clinically and/or agriculturally useful prophylactic or

therapeutic interventions against that agent or toxin or facilitates their ability to evade detection

methodologies.

Example: Creation of Y. pestis (plague) or B. anthracis (Anthrax) that is resistant to all clinically relevant

antibiotics.

Scope of the DURC Policies:

Seven Experiments of Concern4. Increases the stability, transmissibility, or the ability to disseminate a biological agent or toxin.

Example: Creation of an aerosol delivery device for Anthrax spores.

5. Alter the host range or tropism of the agent or toxin

Example: Converting nonzoonotic agents into zoonotic agents, altering the tropism of viruses so they can

infect new host species.

6. Enhance the susceptibility of a host population to an agent or toxin.

Example: Engineering research animals to be susceptible hosts for the select agents covered by the

DURC policy.

7. Generates or reconstitutes an eradicated or extinct agent or toxin.

Example: Information on how to construct a de novo microbial pathogen using unique gene sequences or

combinations of sequences that do not exist in nature; or on how to reconstitute a pathogen that no longer

exists in nature, such as the 1918 pandemic influenza virus.

Scope of the DURC Policies:

The Definition of DURC

Additionally, other research meeting the definition of

DURC (below) may be considered as DURC.

“Dual use research of concern” (DURC) is life sciences

research that, based on current understanding, can be

reasonably anticipated to provide knowledge,

information, products, or technologies that could be

directly misapplied to pose a significant threat with

broad potential consequences to public health and

safety, agricultural crops and other plants, animals, the

environment, materiel, or national security.

2014 U.S. Government Policy on DURC

2014 Policy on Institutional Oversight of

Dual Use Research of Concern

In September of 2014 the U.S. Government issued an

additional policy on institutional oversight of dual use

research.

The 2014 policy goes into effect on September 25, 2015

and provides a framework for local oversight of life

sciences research.

The UNC policy on Dual Use Research of Concern ensures

compliance with the 2012 and 2014 federal policies.

Requirements Under the 2014 DURC

Policy

• Institutions will be required to certify, or attest, to complying with the

federal DURC policy on applicable grants.

• Institutions must provide DURC training to individuals working with

applicable agents.

• Institutions must name an ICDUR, the Institutional Contact for Dual Use

Research of Concern. (UNC Biological Safety Officer)

• Institutions must establish an IRE, Institutional Review Entity, to review

DURC. (At UNC, the IRE is a subcommittee of the Institutional Biosafety

Committee)

• DURC must have an IRE approved risk mitigation plan.

• The risk mitigation plan must be approved by the funding agency.

• Non-compliance may result in suspension, limitation or termination of

funding or loss of future funding opportunities for the project or

Institution.

PI Responsibilities

-Assess their own research and the research of those under their supervision for dual use potential and report as appropriate;

-Stay abreast of literature, guidance, and requirements related to dual use research, and particularly Dual Use Research of Concern (DURC);

-Ensure that their lab personnel are able to identify DURC and manage it properly;

-Conduct research responsibly, especially research that may meet the criteria for DURC;

-Give thought as to how the results of such research should be communicated to others, including the public; and

-Always be alert to potential misuse of research.

PIs/Researchers should cultivate and sustain a culture of responsibility, accountability and safety!

UNC’s Responsibility

UNC’s Institutional Biosafety Committee (IBC) and

Environment, Health & Safety (EHS) Biological Safety

section currently reviews research proposals (Schedule

G) & determine if they qualify as DURC.

If a protocol meets the criteria for DURC, the

Investigator will be asked to submit a risk mitigation

plan for review by the IRE. Further safety measures

may be taken or if necessary the protocol may be

revised or retracted. The IRE approved risk mitigation

plan must be approved by the funding agency before

the research can commence.

Framework for assessing & managing risk:*5 Key Questions:

1. Could this research yield information that could be

intentionally misused to threaten public health, safety and

security?

2. What is the nature of the threat that could be posed from

intentional misapplication of the information & what are the

potential consequences?

3. Based on questions 2&3, how reasonably anticipated

is it that the information could be used to pose a threat

to public health, safety and/or security?

*http://oba.od.nih.gov/oba/biosecurity/documents/B_Dual_Use_Educational_Module_FINAL.pdf

Framework for assessing & managing risk:5 key questions (cont’d)

If potential risks outweigh the

potential benefits, determine

whether research should be

modified, delayed or

discontinued.

Framework for assessing & managing risk:

4. Could this research yield information that could potentially

benefit the life sciences and/or public health, safety or

national security?

5. Do the potential risks outweigh the potential benefits??

Process Overview

DURC?

Notify Funding

Agency (30 days)

Assessed as DURC,

IRE Review

No

Yes

• Notify Funding

Agency (30 days)

• Provide Risk

Mitigation Plan

(90 days)

End

Funding Agency

provides initial

response (30 days)

and finalizes plan

(60 days)

Start

PI’s Initial

DURC

Assessment

Not DURCStandard grant

submission

process

End

Conduct Research in

accordance with plan

Annual IRE

Review

Notify

Funding

Agency

When

Project Ends

Initial DURC Assessment

i. Research involves one or more of the agents or toxins listed in the DURC policy;

And

ii. Research with one or more of the agents or toxins listed in the DURC policy also

produces, aims to produce, or can be reasonably anticipated to produce one or more of

the seven experimental effects listed the policy;

Or

iii. Research that may meet the definition of DURC.

Fink Committee of the National Research Councilof the National Academies, USA (2003):

“Even experiments that have the greatest potentialfor diversion to offensive applications or terrorist purposesmay also have potentially beneficial uses for public healthpromotion and defense”.

Case Study #1

Reconstruction of the 1918 Spanish Flu (2005)

Dual use concern: The information obtained could be

misused and the virus could be bioweaponized

Biosecurity/Biosafety issues: Were appropriate

precautions taken for containment & security? Were

the results communicated in a way to enhance public

understanding of the need for the research?

Case Study #2

Mousepox Experiment - A strain of ectromelia virus

(mousepox) was bioengineered in an effort to sterilize

mice in Australia. The strain killed 60% of the infected

mice. (2001)

Dual use concern: Many feared that publication of this

research would provide a blueprint for those with

malevolent intentions and a more virulent strain of

smallpox could be created to infect humans.

If you have any questions regarding your research

and its dual use research potential, please contact

UNC’s Biological Safety Officer and Institutional

Contact for Dual Use Research

Dan Eisenman, PhD, CBSP

[email protected]