Location of facilities
89. Currently, all of the UK's ten CL4 facilities
are located in the south of England, although CL3 facilities are
widely distributed.[167]
Some CL4 facilities, such as IAH Pirbright and the laboratories
at Porton Down, are situated in relatively isolated locations
but this is not the case for all. A number of CL4 laboratories
exist in large cities around the world, including three in London
which have been in operation for some time.[168]
Germany is currently building new high containment laboratories
for human pathogens at the Robert Koch Institute in Berlin,[169]
and the Minister for Science and Innovation told us that "there
are more than a dozen cities around the world where containment
level four facilities do operate. I am not aware that there are
any security or biosecurity issues as a result of those."[170]
90. Whilst CL4 facilities may already exist elsewhere
in large cities, the question must be whether these are ideal
locations for future developments. For example, the provision
of additional biosecurity was the primary reason for the movement
in the early 20th century of the Friedrich Löeffler
Institute in Germany onto the Isle of Reims. Modern biorisk management
strategies mean that isolated or island locations are not essential
for high containment laboratories but location is still a consideration.
In the USA, for example, there has been controversy over the possibility
that the Department for Homeland Security will move FMDV research
from its current location on Plum Island, off Long Island in New
York, to a mainland location. The USGAO has concluded that evidence
is lacking that such research can be done safely on the mainland.
It cites the outbreak at Pirbright as the best evidence that that
an island location is preferable since it can help prevent spread
of the virus should an accidental release occur.[171]
In addition, in Boston in the USA, there has recently been controversy
over the location of a CL4 laboratory in the city and the adequacy
of the analyses of worst case scenarios and alternative locations.[172]
91. These issues have acquired resonance in the
UK with the announcement in December 2007 by the MRC, Cancer Research
UK, the Wellcome Trust and University College London of their
intention to establish the UK Centre for Medical Research and
Innovation (UKCMRI), next to the British Library and St Pancras
station in central London. Work carried out at the MRC's National
Institute for Medical Research (NIMR) will move to the new site
as determined by a scientific planning committee chaired by Sir
Paul Nurse, President of Rockefeller University, New York.
[173]
At present the NIMR runs the only MRC-owned CL4 laboratory,[174]
but whether this work will move to the UKCMRI is undecided. Sir
Leszek Borysiewicz, the MRC Chief Executive told us that
we have not put in a specific proposal in this
regard. We are awaiting the considerations of a scientific committee
to determine whether that science is actually necessary on that
site and obviously before going further full security and other
requirements would have to be considered. It is very important
that we are not pre-judging the need or otherwise of such a facility
as I made clear on a previous occasion.[175]
The UKCMRI project has also precipitated the Griffin
review of CL4 facilities described earlier.
92. The idea of locating a CL4 laboratory at
the UKCMRI has generated significant concern in the area and in
the media.[176] Professor
Griffin sympathised, when asked about locating CL4 laboratories
in urban areas:
I would try to avoid it, to be quite frank
because of the danger of spills or breakdown of facilities;
because of what would happen if there was a very major leak,
and if that leak was perhaps even terrorismrelated, to the
general population.[177]
He later qualified this by telling us that:
Whilst I stated that I would wish to avoid situating
a containment level 4 facility in a major conurbation, I would
like to make it clear that decisions of that nature are informed
by multi-factorial risk assessments in which scientific benefits
are viewed in the context of potential risks.[178]
93. As the regulator, the HSE is content that
it would be safe to have a CL4 laboratory operating in London
"as long as it was designed, operated, maintained and run
properly".[179]
Professor Chris Thorns of the VLA concurred, telling us that:
the location of Category 3 and Category 4 laboratories
is part of an overall risk assessment. It is one important component.
There are other equally important components which include availability
of scientific and support expertise, the availability of maintenance
staff, the closeness to emergency services and other support teams
and communication links
Personally I do not have a problem
with a Category 4 facility sited in a fairly highly densely population
provided the risk assessments are transparent and have been carried
out properly.[180]
94. We heard general agreement that consulting
the HSE at an early stage was advisable when building new CL3
and Cl4 facilities.[181]
Dr Paul Logan of the HSE told us that its inspectors "are
consulted about plans for level four facilities. For level three
facilities we encourage people to approach HSE
At the moment
we would have the powers to stop the level four facility if we
thought it was not going to be able to operate safely."[182]
Lord McKenzie told us that he did not believe that the HSE's approval
should necessarily be required for a proposed high containment
laboratory.[183] However,
there is an argument that the HSE should be required to approve
an application to build a CL3 or CL4 laboratory early in the planning
process to ensure that it is likely to meet the required standards,
preventing the possible waste of resources.
95. We consider that there is no reason in
principle why CL4 laboratories should not be built in urban areas,
provided that the correct risk assessment is undertaken and biorisk
is managed appropriately. As each case will be unique, we recommend
that such applications be treated on an individual basis.
96. We recommend that the HSE be a statutory
consultee in any planning application for a CL3 or CL4 laboratory.
110