Michael GottesmanMichael Gottesman
The recent contamination of a water cooler in Building 37 with phosphorus-32 has raised important issues about how we protect NIH staff. Although we are a diverse community, spanning multiple campuses and a wide range of professions, we share a desire to minimize threats to our safety and security. The tough question is, how can we create a safe, secure work environment without destroying the open intellectual atmosphere essential to biomedical research?
In my view, there are two general categories of safety and security risks. First, there are risks such as fires and chemical spills that pose an immediate danger to the health and well-being of NIH staff. There is little controversy about the importance of minimizing or eliminating such risks. The second set of risks such as recombinant DNA activities and exposure to low-level radioactivity-risks that do not constitute an immediate threat to health or safety-is more problematic.
In the first category, the danger of exposures to fire, toxic chemicals, pathogenic organisms, and high-voltage equipment is a fact of life in the modern laboratory. Fortunately, scrupulous use of appropriate safety equipment and precautions, proper training, and maintenance of clear corridors can greatly reduce the chance of lab accidents and facilitate emergency response when accidents do occur.
A different sort of concern in the first category is the threat of criminal acts such as theft, personal assaults, and violent action by malicious individuals or groups. Although rare, such events do occur at NIH. To guard against crime, NIH police patrol the campus and we all take precautions such as locking unoccupied labs, limiting access to NIH buildings after normal working hours, and controlling access to buildings that house nonhuman primates. Importantly, any steps to tighten security are taken only after the risks are weighed against the possibility that tougher security measures will interfere with normal research activities. Currently, there is no plan to lock all NIH buildings during working hours because the need for such action has not been shown to outweigh the high cost of hiring enough security guards to provide "true" security and because it would significantly interfere with the normal flow of people and research materials. Our best defense against crime is for everyone to be vigilant, for example, by questioning strangers about the nature of their business in NIH buildings and reporting suspicious or criminal activity to police immediately.
The second category of potential risks at NIH includes factors that do not appear to pose an immediate danger but that, over a period of time, may result in a statistically detectable hazard. In some cases, the long-term health risks are unknown or indeterminable, but a reasonable person might perceive such a risk, or there might be public concern about the possibility of such risk. Activities that fall into this category are experiments involving recombinant DNA research on nonpathogenic organisms and gene products and the use of low-level radioisotopes. Many researchers question rules and regulations in these risk areas that they think serve no useful purpose.
However, recent events underscore the importance of observing all guidelines and regulations for this risk category. You may ask, what does it matter to an individual scientist if a few thousand counts of hydrogen- 3, phosphorus-32 (P-32), or carbon-14 are left contaminating a lab bench, or if a researcher wants to mouth-pipet Escherichia coli carrying a recombinant plasmid encoding human cDNA sequences? First, such activities represent bad laboratory practice, which could lead to sloppy handling of more hazardous materials or organisms. Second, perception and acceptance of risk is very personal. Because we work in a crowded environment, one person's carelessness invariably results in the exposure of others, and it is inappropriate for one researcher to decide whether others should be exposed to questionable material-no matter how small the risk. Finally, deliberate or careless violation of rules and regulations regarding "low-level" risk subjects all of NIH to the possibility of public censure and harsh regulatory sanctions that could make it far more difficult to conduct our daily work.
The recent, apparently deliberate, P-32 contamination of a water cooler and perhaps of a scientist's food or drink in Building 37 illustrates some of these points. Although the exposures should not pose a health risk to any of the staff involved, the attendant negative publicity led to questions about our security and handling of radioisotopes and demonstrates the potential price of problems in this arena. I cannot overemphasize the emotional distress experienced by the affected individuals, the exacerbation of mistrust within our local community, and the intensity of demands that NIH "do something" to prevent such an event from recurring.
Last year, NIH suggested to the Nuclear Regulatory Commission (NRC) that security governing the storage and use of certain radioisotopes, including P-32, be relaxed to facilitate their use within labs. When the P-32 contamination occurred on June 28, NIH was undergoing an NRC inspection to determine, at least in part, the effectiveness of our security arrangements for radioisotopes and whether our request for less stringent restrictions should be granted. Although our request was based in good faith on known risks, it did not take into account the dramatic nature of any contamination with radioactive materials and the emotional reaction to such contamination. I believe that our decision to withdraw that request, to strictly enforce current security regulations, and to search scrupulously for other possible contamination - with only negative results so far - has been a reasonable response to the P-32 case. In fact, the NRC recently gave us high marks for the overall quality of our radiation-safety program.
Although we may wish to govern ourselves by safe and appropriate research practices, the reality is that NIH is governed by oversight bodies such as the NRC, the Occupational Safety and Health Administration, and the Environmental Protection Agency. One of my responsibilities is to enforce safety regulations, but another is to explain to regulators the special circumstances that affect NIH research activities. The good working relationship that we have with regulatory agencies today is due in no small part to the reputation that NIH has developed as an institution that is responsive to public concerns. I hope that everyone will work with me to maintain and foster this good reputation.
Michael Gottesman
Deputy Director for Intramural Research