Training
125. The VLA describe the availability of trained
staff as an "essential component" of capacity to carry
out work at high containment.[239]
The regulatory framework is confused in this area. For example,
employers have a general requirement under Health and Safety law
to provide adequate training, GMO(CU) regulations require specified
training to be undertaken and COSHH regulations set out guidelines
for the content of training.[240]
Dr Matthew Penrose of the HSE told us that:
The regulatory requirement is that it is left
to individual organisations and sites as to how they want to train
their staff
In the university setting there is not that
legal requirement for all staff to be trained to a common level.[241]
126. We found that the provision of training
in biorisk management and the handling of pathogens is not well
co-ordinated, At present individual organisations are responsible
for providing training and thus approaches vary. This is also
the situation internationally.[242]
Organisations run their own training schemes[243]
which may not be readily transferable. ISTR told us that provision
at a local level allows for a significant variation in the quality
of training and perpetuates local practice, whether or not this
is ideal.[244] However,
we were told by organisations representing scientists that there
is no evidence of a widespread failure to train staff adequately.[245]
Dr Matthew Penrose of the HSE told us that "in practice we
find that organisations do train their staff."[246]
127. Both laboratory managers and BSOs have a
key role in biorisk management and require tailored training,
especially since at present they are often responsible for training
other staff in the laboratory. We heard support for a formalisation
of their training[247]
as is in progress in Switzerland.[248]
128. Some formal training courses for staff at
various levels do exist. For example, the MRC runs a course for
BSOs while both HPA and MRC run courses for those working in Containment
Laboratories.[249]
HPA is planning a purpose-built training facility at the Porton
Down site which will be able to train up to CL4.[250]
The ISTR is currently developing an accreditation programme for
training providers,[251]
and there is collaboration between the MRC and ISTR on the future
of training programmes for biosafety professionals.[252]
The ISTR and Robert Osborne, Biological Safety Adviser at the
University of Glasgow expressed support for these initiatives
and their extension.[253]
129. The development of standardised training
regimes would be one way to ensure a uniform, high standard of
staff training and would in addition give high containment work
a more professional status.[254]
Professor Griffin told us that Medical Laboratory Scientific Officers
carrying out diagnostics in containment laboratories in the NHS
have a structured training and accreditation programme.[255]
Introduction of a similar scheme for all those handling dangerous
pathogens could provide reassurance to employers that a basic
level of competence has been reached. Conversely, given that those
running a facility have ultimate responsibility for safety and
training, some might prefer to continue to train individuals from
scratch, to their own satisfaction. We heard strong support across
the board (scientists, the HSE, funding bodies and Government
Agencies) for a transferable certification of competence for working
in high containment laboratories.[256]
However, a number of witnesses were adamant that any certificate
could not be relied upon completely and that certified training
programmes should be minimalist, providing a baseline to be built
upon with 'on the job' training using specific pathogens under
local conditions.[257]
Sir Leszek Borysiewicz, Chief Executive of the MRC, told us:
we must not overlook
where the primacy
of the responsibility for the safety of the individuals actually
participating and working in such an environment actually resides
if I were running a Category 3 facility I do not care how
many bits of paperwork a technician or a member of staff actually
has, until they prove to me they are competent and are not endangering
themselves or others I will not sign off that individual to actually
operate in that sector.[258]
130. Unlike in other countries, undergraduate
and masters programmes in the UK rarely include training in biosafety
and biosecurity.[259]
Sir Bill Callaghan told us that:
there was an HSE commissioned report some years
ago which recommended that health and safety should feature in
undergraduate courses
we did not get as far as we would
have liked because ultimately the responsibility for courses lies
with the academic institution.[260]
The introduction of such content received support,
including from the Minister for Science.[261]
131. We recommend that the Government co-ordinate
the funding and development of training schemes for those working
with dangerous pathogens, building on schemes currently in existence.
These should provide certification that a minimum level of competency
has been reached and should be designed as a base from which staff
can be further trained locally in the safe use of specific pathogens
in a particular laboratory. Training programmes should be tailored
to the needs of laboratory staff, principal investigators or BSOs
whose training needs differ.
132. We recommend that DIUS engage with the
higher education sector to ensure that undergraduate and masters
programmes in relevant subjects include instruction in biorisk
management.
Vetting of staff
133. Laboratories working with dangerous pathogens
are potential targets for those wishing to acquire pathogenic
material or training in its handling for malicious purposes. Recognising
the threat, in April 2005 the Association of Chief Police Officers
and the Home Office published a guide to 'Personnel Security Standards
for Laboratories' and circulated it to laboratories subject to
Part 7 and Schedule 5 of ATCSA. However, security clearance for
scientists working with dangerous pathogens is still not harmonised
in the UK and for Home and EU staff or students security-vetting
is not always a prerequisite for work with dangerous pathogens.[262]
134. Security procedures for laboratories differ
according to containment level:
CL 4 laboratories are subject to extensive security
measures with extremely limited access. All staff granted access
must undergo security clearance.
CL 3 laboratories are subject to security measures
required by ATCSA and receive bespoke advice regarding staff security
checking.
CL 2 laboratories are provided with bespoke advice
regarding physical and personnel security by Counter-Terrorism
Security Advisers.[263]
135. It is standard practice in Government-run
laboratories that staff are security-vetted using Government vetting
programmes. The HPA security-vet all those working at ACDP4 to
SC level[264] and the
VLA subjects all scientific staff working at or above CL3 to counterterrorism
checks, insisting that visitors are accompanied or undergo training
and security-checking on the same basis as their staff.[265]
Outside Government agencies, for example in universities, Research
Council Institutes and the private sector, standards of security-vetting
vary.[266] On our visit
to Pirbright we were informed that IAH, despite undertaking contract
work for Government departments, use a professional, private vetting
agency for all staff working at CL4 because the institute does
not have access to Government vetting schemes. We can see no reason
why the ownership and governance of a laboratory should alter
the necessity of reliable security-vetting and are concerned by
the apparent lack of standardisation in this area, given its importance
to national security.
136. In other countries such as Germany, Japan,
Canada and others security vetting is a matter for the institution.[267]
In the USA any organisation using a 'select agent' must provide
a list of those staff involved in the project. The FBI then conduct
finger-printing and background checking for these staff.[268]
137. For vetting of overseas students, a new
system, the Academic Technology Approval Scheme (ATAS), was introduced
in November 2007, administered by the Foreign and Commonwealth
Office. Non-EU nationals applying to study sensitive subjects
must hold a valid ATAS certificate specific to a Higher Education
Institution (HEI) and programme of study before applying for entry
to the UK or for an extension of their stay. The rules apply to
research students and those undertaking masters programmes in
some subjects. ATAS replaced the Voluntary Vetting Scheme under
which HEIs were able to refer students to the FCO for vetting
and received a recommendation on the suitability of the student
for the programme. This scheme was considered burdensome and provided
only patchy coverage of HEIs since it was discretionary.[269]
Both Universities UK and the Research Councils are satisfied that
ATAS is operating successfully.[270]
However, as a new scheme, ATAS has not been in operation through
the peak period for student admissions and there are concerns
that increases in throughput may impact on turnaround time.[271]
138. There was widespread agreement in the evidence
that security procedures should not restrict international movement
of staff as part of free academic exchange.[272]
In addition, the SGM, IAH and Astrazeneca highlighted that
UK laboratories play a key role in training personnel from developing
countries who are subsequently instrumental in controlling diseases
at source.[273] It
is possible that security vetting will, to some extent, restrict
the movement of staff but ideally the vetting system should not
deter bona fide staff from studying and working in the
UK.
139. Security-vetting is intended to minimise
the risks of deliberate misuse of dangerous pathogenic material.
This risk exists regardless of the ownership and governance of
a laboratory or the country of origin of researchers and other
staff. We therefore recommend that the Government provide access
to Government vetting programmes so that all those working with
CL4 pathogens can be reliably security-vetted to a consistent,
high standard.
226 Ev 51 Back
227
Ev 68, 98 Back
228
Ev 157 Back
229
Qq 225, 227, 228; Ev 98 Back
230
Q 225 Back
231
Q 379 Back
232
Ev 64; Qq 225-226, Back
233
Qq 225-226 Back
234
Q 227; Ev 93 Back
235
Q 285 Back
236
Ev 107 Back
237
Qq 284-285 Back
238
Ev 68 Back
239
Ev 64 Back
240
Ev 58 Back
241
Q 142 Back
242
Ev 125, 128, 134, 136, 139, 145, 148 Back
243
Ev 64, 69, 71, 73, 80, 98, 104, 115; Qq 44, 142 Back
244
Ev 69 Back
245
Ev 98, 115, 157 Back
246
Q 142 Back
247
Ev 82, 91 Back
248
Ev 148 Back
249
Ev 66, 78, 93, 119; Qq 46, 223 http://www.wellcome.ac.uk/stellent/groups/corporatesite/@policy_communications/documents/web_document/WTX041321.pdf
Back
250
Q 223 Back
251
Q 144; Ev 69 Back
252
Q 221; Ev 78, 91 Back
253
Ev 69, 78 Back
254
Q 297 Back
255
Q 46 Back
256
Qq 45, 146, 297; Ev 70 Back
257
Qq 44-45, 65-69, 78, 221-223, 297-298 Back
258
Q 221 Back
259
Ev 69; Q 59 Back
260
Q 60 Back
261
Qq 59, 380; Ev 123, 133; http://www.wellcome.ac.uk/stellent/groups/corporatesite/@policy_communications/documents/web_document/WTX041321.pdf
Back
262
Ev 69 Back
263
Ev 57 Back
264
Ev 119 Back
265
Ev 64 Back
266
Ev 64, 95, 97 Back
267
Ev 125, 126, 129, 132, 134, 136, 145 Back
268
Ev 139 Back
269
Ev 62 Back
270
Ev 94, 111 Back
271
Ev 112 Back
272
Ev 63, 69, 74, 104, 116, 124, 153 http://www.wellcome.ac.uk/stellent/groups/corporatesite/@policy_communications/documents/web_document/WTX041321.pdf
Back
273
Ev 105, 124, 153 Back