UK Centre for Medical Research and Innovation

Written evidence submitted by
St Pancras and Somers Town Planning Action (UKCMRI 11)

Please find attached submission from SPA (St Pancras and Somers Town Planning Action) to the Select Committee Enquiry into the UK Centre for Medical Research and Innovation

SPA, as a representative of the residents of St Pancras and Somers Town, (and as UK citizens, residents and taxpayers) has two primary areas of concern about the UKCMRI plan: safety and cost.

Safety

Europe’s biggest such laboratory researching ‘killer diseases’ should not be sited in Brill Place, Somers Town, near to St Pancras Station, Europe’s biggest transport terminal, and at the heart of a crowded residential community, in light of the risk of

a) an escape of pathogens into the atmosphere, or of infectious material via the water table into adjacent railway tunnels, or of

b) the laboratory attracting international terrorists or animal rights activists that cause an escape through their actions.

Cost

At a time of severe budget restrictions, with the science community fearing a 25% reduction in funding for research, spending £600m (£220m directly from public funds) on a building (with a further estimated £100m annual running costs) is not a sensible allocation of resources. No evidence has been presented for claims of the benefits of such a building.

Natalie Bennett, chair,

St Pancras and Somers Town Planning Action

12 January 2011

Written submission from SPA (St Pancras and Somers Town Planning Action)

Background:

Like the Science and Technology Committee report of 2008, we at St Pancras and Somers Town Planning Action (as local residents, and UK citizens, residents and taxpayers) welcome and support the concept of the creation of a leading medical research centre based in the UK. But we are opposed to the UKCMRI – Europe’s biggest biomedical laboratory researching ‘killer diseases’- being located beside Europe’s biggest rail terminal at St Pancras, and in close proximity to densely populated Somers Town. We believe that such ambitious medical research should further evolve on the 47 acre site at MRC Mill Hill, instead of the 3.6 acres at St Pancras. We are a group of residents who have long been opposed as individuals to the UKCMRI proposals and other encroachments in our ward, and formed our organisation in June 2010 (following years of earlier community meetings).

Terms of reference:

1. We acknowledge that UKCMRI have improved their proposal since 2008 in the appearance of the ‘superlab’ but we maintain that it is unsightly and unsympathetic and dominates its surroundings, as it is the equivalent of a massive factory structure in an urban and domestic setting, having to accommodate 1500 scientists and others in a small space.

2. In assessing the plans for the coming years, we would draw the Committee’s attention first to

a) The excavation. UKCMRI will descend four floors below ground level, and in so doing face the same challenges as The British Library did on the adjoining site, where it was necessary to drive foundations down more deeply than at most other sites in London, and where flooding of the basement delayed construction considerably. The descent will be through the water table, which will continue to flow around the foundations, and be a potential carrier of contagious matter into railway tunnels should such escape at any time in the future (as with Pirbright). Construction delays and competition for competent workers during the development of Olympic sites will raise costs. Noise and pollution from the massive excavation and from the haulage of spoil will oppress the local community and irritate drivers for years to come. These will be costs to the community and to London.

b) Operation. The Northern tube line will run beneath UKCMRI. Its vibrations (at present felt in the basement of The British Library) will disturb the functioning of sensitive instruments necessary for research. The cost of shielding them from such vibrations will be a high one.

c) The need for expansion.

Clustering 1500 scientists and staff into one building will be a challenge if they are to work effectively. Having contracted the working site from 47 acres at Mill Hill to 3.6 acres at Brill Place, what will happen if some of the staff of 1500 instigate projects which need more space? Research teams, including those representing pharmaceutical companies, will be invited to bid for space and facilities. As these become scarce, one assumes that priority will go to the bids that pay the highest, and these will be from pharmaceuticals, over whom UKCMRI and other authorities will have less chance of effective supervision (as with Pirbright). Pure scientific research will be less frequent, increasingly so as translational projects are given priority.

The advantage of space in relation to animal use at the Mill Hill site (only 25% occupied) is highlighted in a written Annexe to your committee of 8 February 2005 (attached)

The memorandum of Steven Ley of NIMR on the advantages of Mill Hill and the inexplicable preference for central London are in Appendix 70 to your committee on 22 November 2004 (attached)

2. Hoped for achievements.

a) We respect UKCMRI’s aims to have ‘a world leading research centre that will tackle diseases that affect us all’ (John Cooper, Interim Chief Executive, Camden New Journal 16 September 2010). UKCMRI will involve numerous hospitals and research centres in the Bloomsbury/Euston area.

b) However we believe those aims could be achieved much more safely, economically and ambitiously by expanding the existing facilities at the National Medical Research Institute on its 47 acres site at Mill Hill, rather than by being confined to 3.6 acres at Brill Place. MRC Mill Hill enjoys relationships in translational science with laboratories all over the world, and works in collaboration with Cancer Research UK, the Wellcome Trust and University College London. Why should not that configuration be renowned as Europe’s leading research institute sharing several sites, and maintain Britain’s position at the forefront of global medical research, strengthening the UK economy and through links with the NHS, change patients’ lives? Are these aims not being pursued at present? Why leave Mill Hill where space exists for truly ambitious expansion for decades to come? Why confine Europe’s leading research centre to 3.6 acres? Plan for the future, rather than succumb to the short term attraction of ‘a cathedral for science’ in a prime, but cramped and unsafe location. It is assumed that UKCMRI wish to be established for many decades, long after the individuals at present leading it, and their particular priorities, have been replaced by successors with their own priorities.

c) Statements from UKCMRI suggest that the St Pancras site, within walking distance for the partners, and a convenient address for visiting scientists, will uniquely facilitate research because face to face communication will speed the research process significantly. We have asked them to produce a peer reviewed paper saying that this must be so, to no avail. We implore them to endure the sacrifice of less frequent meetings and the journey to Mill Hill, and assisted by e-mail, post and telephone, undertake research without the risk of a contagious spillage or errant pathogens infecting a community and an international transport hub.

d) In Science 23 July 2010 , VOL 329 NO 5990, pp 380-381, Sir Paul Nurse described his vision for UKCMRI "One reason size is important is to have a multidisciplinary approach. Because it’s large, it doesn’t actually have to have a particular focus….About two-thirds of the 120 research groups will be at the junior end, in their 30s to early 40s..It won’t be divided into academic departments and divisions…Individuals can belong to several interest groups, they can withdraw from one to join another’.

e) Asked about the push for more translational research, Sir Paul said :"I’m beginning to think nobody has got on top of this properly. It’s worth looking at freshly. We have basic scientists, we have clinicians, we have the pharmaceutical industry."

This suggests that the principles and modus vivendi of translational research have yet to be ascertained. Surely then it’s safer to do this where there’s more space.

f) UKCMRI has stated that the Centre will accept bids for facilities by outside bodies including pharmaceutical companies, in order to successfully exploit innovations in Britain, rather than the USA profiting from them.. UKCMRI anticipate their activities will attract further capital to their laboratories.

All these factors – ‘translational’ science, blurring of disciplines, financial exploitation of discoveries and outside bids will add to exciting, volatile, unpredictable activity. Wouldn’t there be more and safer scope for this at Mill Hill? Wouldn’t that be a safer long term investment?

g) According to Sir Paul Nurse, ‘the UKCMRI will provide the critical mass, support and unique location to tackle difficult research questions’. Does not ‘critical mass’ imply that researchers could get in each other’s way? Does not a ‘critical mass’ of 1500 staff on 3.6 acres imply a uniquely cramped location?

3. The financing of UKCMRI : -

a) Who can be sure that it’s robust, given the possibility of cost overruns? £660 million in construction costs, of which government gives £220 million. We hear that running costs will be £100 million a year. What additional costs will accrue from dealing with the water table and potential flooding? What additional costs from protecting sensitive scientific instruments from interference from train vibration? What other costs from endeavouring to ensure that no pathogens escape? What costs from safety measures (4 below)?

b) The financing of UKCMRI is not justified, because £660 million (£220m from government) plus cost overruns will be spent on the construction of an exotic building taking several years, before any scientific research is carried out there. The £220 million should go not on a building, but immediately to scientific research and to education. The proportion of the £660 million which Cancer Research UK will contribute should go directly to research and not be spent on a building. The thousands of contributors donating to cancer charities would surely prefer an immediate application of those funds to research, rather than to a pretentious building

taller than St Pancras Station that dwarfs and cuts off sunlight from nearby dwellings in an already disadvantaged community with many health problems.

c) There is little public support for the project in the St Pancras/Somers Town Area.

Camden Council recently posted 700 letters to dwellings in the area close to the proposed ‘superlab’, seeking their responses. Ossulston Tenants and Residents Association, comprising 456 dwellings replied filing their objection and took part in a deputation. Others local groups which objected were Winston Tenants’ Association, St Pancras and Somers Town Planning Action, King’s Cross Conservation Area Advisory Committee, Camden Town Urban Design Improvement Society, RMT (offices locally) PCS Trade Union British Library Branch, Camden Friends of the Earth. Other objectors included the 20th Century Society, Action for Our Planet and The Animal Protection Party. Opposition was generally regarding safety and the architectural inappropriateness of the building to those around it. Savage cuts to important services, including centres for the young and for the elderly, dispose local residents to resent and despise the propose ‘superlab’ despite the enticement of ‘sweeteners’ to the value of £10 million. Most of our neighbours prefer long term safety rather than a ‘cathedral for science’ which might cause disaster while claiming to be for the good of their health.

4. a) The risk assessment arrangements to ensure the safety of the site must acknowledge the possibility of a dangerous leakage at some time in the future, no matter what care is taken in construction. We published a long list of British laboratories fined in recent years for leakages (attached), to which UKCMRI replied: "Our scientists have an exemplary safety record". They could not claim "a perfect safety record", which would be preferable before siting UKCMRI where they intend. As their scientists do not have a perfect safety record, yet they wish to ensure there is no spillage, their construction and supervision and waste disposal costs must be far higher than at Mill Hill – and there will still be no absolute guarantee of safety. This leaves the possibility of an infection spreading through the local close, dense population, and through the railway tunnels at St Pancras International.

b) On October 4 2010 in a public meeting called by SPA, John Cooper acknowledged that the level of virulence with which UKCMRI would be experimenting could vary over time. We understand that MRC Mill Hill experiments up to level 4. Camden Council’s planning department recently acknowledged that UKCMRI envisaged experiments up to level 3+. What is the point of spending £660 million on a biomedical research centre if you are not equipped and prepared to experiment on all known viruses? We would be grateful if the Committee could address this question.

c) Risk assessment must also take into account the difficulty of effectively vetting all security staff and laboratory workers – in fact everyone in the building – if a possible internal terrorist threat is to be safely avoided. This will be expensive and painstaking for as long as UKCMRI is in operation.

UKCMRI’s security management plan envisages elaborate safety measures, including maximising the stand-off if a vehicle carrying explosives is driven towards the laboratory, Such measures aren’t foolproof, e.g. in Iraq.

A demonstration by animal rights activists could damage the building and result in a spillage.

d) Though UKCMRI are negotiating a financial payment to the police for extra security, this is a further expense that will be greater because of siting UKCMRI in such a prominent and sensitive position.

If any of the above hazards occur during the next 50 years, the results could be calamitous, as UKCMRI evacuates 1500 people, The British Library evacuates 1000 staff and readers (as has happened before) and St Pancras station has to be evacuated (as has happened frequently). If the railway system becomes infected, how far will this spread? How long before decontamination can be guaranteed and public confidence returns? Can the cost be born? It must be contemplated.

5. Whatever existing arrangements exist for the closing of NMRI at Mill Hill, these should be put on hold until the implications of cost and safety for UKCMRI are re-considered, in relation to cheaper and endless options of expansion at Mill Hill, and the critical need for funding of science and general education in Britain today.

Recommendations for action by Government

a) UKCMRI should be encouraged to seek alternative locations and configuration including Mill Hill, by which UKCMRI could achieve its aims with less risk, less cost, less impact on the landscape and on the local community. It should be encouraged to put money into actual scientific research, and ensure that government funds are so directed, rather than a fancy building.

Brill Place should be used for mixed development including housing as originally intended by Camden Council, with a children’s playground providing space into which passengers at St Pancras or staff and readers at The British Library could go during the evacuations which occur there.

b) Though there have been architectural costs relating to UKCMRI at Brill Place, it would be safer and more cost effective for the laboratories to be sited in safer, more spacious alternative locations.

APPENDICES

Written statement by NIMR employees 2005

 Whilst the Division of Biological Services remains optimistic about the future of MRC's NIMR in partnership with UCL or KCL we foresee a number of major disadvantages to moving away from the Mill Hill site. These are principally:

  Loss of potential for expansion.  The current Mill Hill site is located on a 47 acre site, only a fraction of which has been built upon. There is more than adequate space for expanding the animal facilities within the current buildings as well as constructing new units/buildings on the site within the secure perimeter fence. Future changes in legislation are likely to require larger rodent cages-therefore the space required to house our current numbers of animals is likely to increase, this can easily be accommodated at Mill Hill and must form part of the considerations of a site elsewhere.

  Loss of flexibility.  The animal facilities occupy six buildings on the current site, all within a short distance from the main building. This provides unequalled flexibility to house different species, meet the needs of changing science and changes in legislation. The health status of the different units can be managed individually within central control minimising any disruption to the science in the event of a microbiological breakdown and the flexibility to treat, contain or rederive stocks quickly and efficiently.

  Reduced access to research models.  All the current animal facilities are within easy reach of the main building and therefore scientists and support staff have access and a hands-on approach to the use of animals in their research. This is extremely important to ensure best use of animals and a responsible attitude to using animals in research with easy communication with animal care staff and experienced animal technicians. This ensures work is done promptly whilst ensuring the highest standards of care & welfare. We firmly believe that an animal unit remote from the science cannot encourage or meet best practice or ensure minimum numbers are used.

  Difficulties in staff recruitment.  Many of the animal facilities within central London are experiencing problems with recruitment and retention of animal technicians. This is not a problem at NIMR. Currently, 70 out of 71 posts within Biological Services are filled. Experience from the Mary Lyon Centre should demonstrate the importance of having enough trained and committed technicians to stock a new unit. Experience from many animal units across the UK demonstrates that difficulties arise when there is a mix of MRC & University employees in animal units.

 Waste.  Apart from a waste of money and resources (a new SPF facility was opened at NIMR less than two years ago) the likely increased waste of animals is of concern to many within the Division and Institute as a whole. Currently our operations can provide models to a number of different research groups and sharing tissues and organs is commonplace.

  Inability to recreate containment facilities.  This poses a real problem. Our Containment II to IV facilities have been carefully designed and managed to be able to meet the needs of the current work carried out in them, but also with adaptability and flexibility to be used for new models or potentially emerging diseases.

Loss of training resources.  Our facilities, especially those for Containment of pathogen infected animals, Aquatics and Transgenic species are of importance for training both scientific staff and animal technicians without impinging on the "day-to-day" work of the units. This would be hard to recreate elsewhere.

 Potential loss of SPF facilities.  Our SPF facilities are unique and keep cost of animal supply at a very low level. There is a long list of practical advantages for retaining an MRC SPF supply unit: refinement and reduction of numbers due to critical mass/scale of the operations is a good example. It would be very difficult to recreate new SPF facilities and the time involved would impede progress of science.

  Reduced cost-effectiveness.  Alongside our SPF facilities, the scale of the animal work at NIMR ensures a cost-effective practice-commonly as units decrease in size they become more expensive to run and maintain.

  Likely animal rights protests.  Experience from Oxford and Cambridge indicates a likely problem from animal rights activists during the construction of new animal facilities.

  Additional security problems.  It is unlikely that the protests that are observed on a Wednesday at Mill Hill will go away. The experience in dealing with this, and the safety of the site should not be ignored.

  Time involved in moving animal models.  Duplication of models. Even if the SPF units could be moved as they stand, the remaining models at Mill Hill will need to be recreated elsewhere. This is a mammoth undertaking, as well as likely to increase the numbers of animals used (surgical rederivation of strains) and a huge and needless cull of animals at Mill Hill. There would be a significant time involved to recreate lines (see Mary Lyon centre) and therefore a delay in productive science.

  Accessibility of site for deliveries etc.  The Mill Hill site is easily accessible for the continual need for deliveries of animal food, bedding and other essential supplies. Central London will have reduced access and is therefore a huge disadvantage.

  MRC-T's reliance on animal units.  MRC-T currently requires the facilities of NIMR for translational research requiring animal models-loss of the Mill Hill facilities would be a huge blow to their work.

Kathleen Mathers

Steve Clements

Pete Dawson

David Key

RoseMary Murphy

Paul Lynch

Sarah Johnson

Marie Caulfield

Clare Brazill

Alec Gallagher

Alison Collyer

Treena Carter

Select Committee on Science and Technology

Appendix 70

Excerpts from Memorandum from Steven Ley, National Institute for Medical Research

  3.  …the Mill Hill site offers enormous advantages over the proposed central London sites. We have extensive research animal facilities (9,000 square metres; housing mice, rats, frogs and fish) which are unique in the UK in terms of their size and "state of the art" capabilities. These animal facilities form an essential part of our research infrastructure. Replicating this on a central London site would be very expensive and also difficult to achieve in view of the likely response from animal rights groups.

5…The Mill Hill site covers 47 acres, of which NIMR currently occupies about 25%. This provides the possibility of considerable expansion in the future, which could be funded by the MRC and also by inward investment from other stakeholders

 7.  The major rationale for relocation of NIMR to central London appears to be co-location with a research medical school in order to enhance clinical collaborations and translational research. However, the current NIMR already has extensive collaborations with clinical groups in London, in the rest of the UK and internationally, as demonstrated in submissions to the Task Force. …At present, we enjoy clinical collaborations with all of the major London research hospitals and their associated academic centres. …We believe that the MRC proposal to relocate NIMR from Mill Hill is associated with considerable risk and uncertainty. …We question whether this is prudent use of public funds.

9. … It is clear from the reports of the Task Force …that the option of NIMR remaining at Mill Hill was not properly discussed at its fifth and final meeting. We consider this a clear failure of management of the Task Force by the MRC. The subsequent decision to exclude the Mill Hill option was reached by e-mail and telephone conversations and agreed by a 5-4 vote. The five member majority was achieved by the casting vote of the Chairman.

22 November 2004

Letter printed in Camden New Journal page 19 , 9/9/10

Leak at Brill Place superlab would be catastrophic

MANY unsafe laboratories fined - - so how safe is a superlab?

As Somers Town residents learn of British research laboratories being fined for lax safety measures, they are amazed that the site proposed for UKCMRI – Europe’s biggest biomedical research centre - is right beside Europe’s biggest transport terminal.

Plans for the ’superlab’ were submitted to Camden Council on September 1. The proposed site had been zoned by Camden Council for housing and community facilities.

St Pancras and Somers Town Planning Action (SPA) oppose the construction of the UK Centre for Medical Research and Innovation at Brill Place, opposite St Pancras Station. 1500 scientists and staff would work on ‘killer diseases’ on a site of 3.6 acres. The Medical Research Centre is on a site ten times larger - 36 acres at Mill Hill. But UKCMRI told a parliamentary select committee in 2007 that Mill Hill would be sold – along with the National Temperance Hospital – to help pay for the new centre costing £600 million. This would leave UKCMRI with no large safe sites for experiments.

SPA have learned of several laboratories being fined for lax safety, and wonder how many such cases have been unreported. The Press (north London) of July 10, 2010, reported that the Health Protection Agency was fined £25,000 after exposing staff at its Colindale laboratory to a spillage of E.coli in October 2007. "Workers were exposed to a potentially deadly 0157 strain of E.coli when more than a million doses of the bug were leaked onto the floor from a trolley of hazardous waste…Judge Martin Stephens QC (at the Old Bailey) said it was only by "good fortune" that staff were not harmed by the spill. The HPA was also ordered to pay £20,166 in costs."

The Guardian of Tuesday April 22, 2008 said it had found "over 70 dangerous incidents in labs and breaches of health and safety regulations aimed at controlling dangerous pathogens over the past 10 years". The Health and Safety Executive brought five prosecutions at universities, research institutes and labs attached to hospitals. Imperial College London was prosecuted twice in 1996 and fined £45,000. It was since issued with an improvement notice in 2003 for faulty disposal of genetically modified micro-organisms. Other cases involved The University of Edinburgh (fined £3,500) and the University of Birmingham (£10,000). The HSE has instigated three crown censures in the past 10 years, allowing it to act against government establishments that are immune from prosecution under health and safety law, such as Porton Down and the Central Science Laboratory in York. In the past five years, HSE issued at least 23 notices for laboratory breaches of regulations re substances hazardous to health, genetically modified organisms and health and safety; 42 investigations relating to diseases and dangerous occurrences in labs.

Dr Ellen Nisbett, a malaria researcher at Cambridge University said: "We are extremely well trained in what we do…But if an accident does happen, it could be catastrophic. You just have to make sure it does not happen or locate the lab in an area where it is not so catastrophic if it does happen."

St Pancras and Somers Town Planning Action

January 2011