Responsibility for biosecurity
40. Whilst the regulatory system provides the
framework within which dangerous pathogens can be handled, ultimately
the responsibility for managing risk lies with those who manage
the site. The ACDP
guidance for running containment level 4 facilities notes that:
Specific functions, such as carrying out risk
assessments, may be delegated down the management chain but it
should be remembered that responsibility for health and safety
management cannot be delegated.
41. A clear definition of where responsibility
for biosecurity lies is vital and it is important on a site of
shared ownership to identify 'the controlling mind' as in the
principles of Health and Safety legislation.
The difficulties that can arise when this is not clear are starkly
illustrated by the outbreak of FMDV at Pirbright, where a number
of problems were identified with the complexity of the governance
on the site and lack of communication between different parties.
The HSE highlighted that in general the situation is improving:
When we do inspections we really have to tease
out who is taking responsibility. What we find when we gather
evidence is that more and more there will be high level agreements
between for example a senior director of a charity and a senior
director of a university.
42. Witnesses emphasised the need for a strong
safety culture to pervade all organisations using dangerous pathogens.
Biological safety officers/advisers (BSOs) are key to successful
biorisk management. The ACDP guidelines emphasise that:
The recruitment of a biological safety advisor
(BSA) is pivotal in ensuring management are provided with sufficient
information and advice to ensure risks related to biological agents
are either controlled or prevented.
There is widespread support for a more high profile
role for BSOs and for giving them professional status.
The Wellcome Trust advocated that the role of BSOs could be built
into the regulatory framework.
43. There should be complete clarity over
who is responsible for biosecurity, especially on a site of mixed
ownership or sponsorship such as at Pirbright. The 'controlling
mind' must be clearly identified and be expected to manage the
risks that it creates. Ultimate responsibility for biosecurity
rests with managers of a facility. A strong safety culture is
essential for good biosecurity and all those who fund and operate
high containment laboratories should ensure that this exists.
44. We support the role of Biological Safety
Officers in enforcing biosecurity and recommend that the Government
and the HSE in particular look at ways to support and reward this
profession appropriately given the level of responsibility it
holds, firstly by establishing a formal accreditation process.