Wednesday, July 16, 2014

First thing we do, let's purge all the advisors!


    My title is a play on the Shakespearean quote from his work, “Henry VI”, “First thing we do, let’s kill all the lawyers!” uttered by Dick the Butcher in hopes that if he could do away with law and order, he could become king. This title seems apropos for the purging of the institutional memory of the NSABB yesterday with the wave of dismissals of 11 of the 23 member FACA (Federal Advisory Committee). Yesterday’s news of the purge of the NSABB in the wake of the CDC and NIH incidents with anthrax and smallpox, raises questions about the reason for making an exception to the charter’s length of service of membership appointments and the very purpose of the NSABB. The NSABB Charter provides that members will be appointed “for overlapping terms of up to four years; . . .”
               The purpose of the NSABB is explained in the charter “. . . is to provide, as requested, advice, guidance, and leadership regarding biosecurity oversight of dual use research, defined as biological research with legitimate scientific purpose that may be misues to pose a biologic threat to public health and national security. The NSABB will provide advice on and recommend specific strategies for the efficient and effective oversight of federally conducted or supported dual use biological research. . .”  This is a very narrow charge, and the NSABB has historically worked in this narrow area.  The scope of authority for the NSABB does not include advice on the proper regulation of federal conducted research --- only that research in the context of its “dual use” implications.  Even a new array of advisors will have no further authority than the existing and purged membership, so it is unclear what the expectations are for this exceptional overturn of membership.

      The Pandemic and All-Hazards and Preparedness Act, 42 U.S.C. 217a, sec. 222, is the authority for the NSABB.  The NSABB is a Federal Advisory Committee which means it is made up of non-government members with government members and is advisory, only.  The NSABB advises the Secretary of Health and Human Services.

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