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4 Review of the USAMRIID Environmental Impact Statement
Pages 42-54

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From page 42...
... Routes for Infectious Agent Release There is a remote possibility that etiologic agents studied in the proposed USAMRIID facilities could exceed their intended containment by any one of a number of routes previously described. Except for animal escape, managed 42
From page 43...
... developed expressly for such high-exposure environments, specifically regarding: air exchange rates, vestive flow regimes, differential pressure systems, staged filtration, and protected heat transfer equipment. While special indoor air quality engineering features were presented in this context, the performance, reliability, and security concerning the operations and maintenance of indoor air quality systems were not addressed in the EIS or its associated hazard assessment.
From page 44...
... Other events described include escapes of laboratory animals, an airplane flown into the laboratory, accidents during pathogen transport to the laboratory, and exposure through an infected laboratory worker. There is limited discussion of actions taken by a laboratory employee that may circumvent biosecurity measures and maliciously expose members of the community to infectious agents.
From page 45...
... . The EIS used Gaussian plume calculations to estimate the maximum credible risk posed to the general public by the aerosol releases described above.
From page 46...
... Considering a range of common meteorological conditions over the course of a year, it was determined that pathogen concentrations were insignificant at ground level beyond 300 meters from the points of release in all scenarios, the shortest distance to the Fort Detrick fence line. These results were considered conservative because of the large puff size and an infinite environmental halflife of selected pathogens, which ignores natural decay and environmental factors that can significantly affect viability and infectious potential.
From page 47...
... In cases involving communicable agents, a single index case of infection can have disproportionately large adverse public health consequences if effective control measures are not in place. Two laboratory-acquired infections from the past decade have demonstrated that laboratory personnel can mediate significant public exposure (see Chapter 2)
From page 48...
... Such analyses would identify maximum credible risks, and would also provide guidance for the on-going mitigation of risk as emerging pathogens are added to the list of research candidates. Other Community Risks The EIS Hazard Assessment addresses the risks posed by laboratory rodents, rabbits, and primates to the public.
From page 49...
... In the latter case, animal caretakers or laboratory workers may be exposed to zoonotic agents, such as Herpes B virus, from contact with laboratory animals; infectious aerosols shed in urine, blood, and other body secretions; or pathogens from bites and scratches (either from caged or escaped animals)
From page 50...
... . TABLE 4-1 Personnel Hours Worked and Outcomes of Accidental Exposures to Infectious Agents: Intramural National Institute of Allergy and Infectious Diseases 1982-2003 Hours at Risk Bench Animal Total BSL-3 553,000 81,500 634,500 BSL-2/3 Pa 2,235,500 360,200 2,555,200 Total 2,788,500 441,700 3,189,700 Outcomes of Accidental Exposures Other Exposures, Clinical Infections Silent Infections No Infections BSL-3 1 2 9 BSL-2/3 Pa 0 2 15 Total 1 4 24 a P refers to partial, which was used in past practices preceding Biosafety in Microbiological and Biomedical Laboratories requirements.
From page 51...
... For the MCE in a BSL-4 setting, the EIS considered an unrealistic centrifuge failure scenario similar to the one for the BSL-3 scenario, with Ebola virus as the infectious agent. Except for the Reston Ebola virus, which primarily infects non-human primates, Ebola is spread by direct contact with infectious blood or other bodily secretions and is not known to be transmissible by the aerosol route (Pourrut et al.
From page 52...
... . CONSIDERATION OF ALTERNATIVE CONSTRUCTION SITES The EIS provided an ample and compelling rationale for why personnel in the new facility would not be able to effectively perform their mission -- which is in part dependent on leveraging complementary capabilities of the National Biodefense Analysis and Countermeasures Center and the National Institute of Allergy and Infectious Diseases' Integrated Research Facility -- if sited remotely from its current location.
From page 53...
... Such an exercise could have provided a comparison that identified advantages and disadvantages specific to each location, and guided preventive strategies and mitigation ef forts if differential risks were found.  Although the EIS hazard assessment failed to provide adequate and credible technical analyses, it was determined in Chapter 2 that current procedures, regulations, physical security, and biosurety guidelines at USAMRIID meet or exceed accepted standards and practices.
From page 54...
... 54 Health and Safety Risks of New USAMRIID High-Containment Facilities RECOMMENDATION The committee recommends that the Army consider developing detailed and practical guidance for conducting hazard assessments of infectious agents for inclusion in the Army's guidance for implementing the National Environmental Policy Act to improve future EIS processes and products.


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