Councilors,
At the May 21 city council meeting, I spoke about my concern that the Parkline development will place residences and public spaces close to laboratories that perform research involving organisms that may cause serious or potentially lethal disease. I appreciate that Mayor Taylor and Councilor Nash brought up this concern in the subsequent discussion. However, the responses from Mr. Murray of the Land Partners team raised more questions than they answered. In particular, the following concerns should be addressed before the project moves forward:
Regulation of BSL-3 laboratories. Mr. Murray stated that BSL-3 laboratories are heavily regulated. This is partially true. The National Institutes of Health (NIH) biosafety guidelines apply only to labs that receive federal funding. CDC and USDA regulate labs that possess, use or transfer a short list of dangerous organisms and toxins. However, private labs are not required to adhere to the NIH guidelines. Although SRI is a private company, its research is supported by federal grants; thus they are, at least theoretically, audited and inspected. However, tenants of the planned new lab buildings may not have these same requirements. How much detail will SRI provide to Menlo Park and to the San Mateo County Department of Emergency Management on the kinds of research conducted and the specific organisms or animals used? How does SRI propose to ensure biosafety for labs that they do not operate?
Scope of Bioscience Research. On May 6, 2024, concerns about inadequate regulation of bioscience labs prompted the Biden Administration to issue new guidelines for labs that engage in “Dual Use Research of Concern and Pathogens with Enhanced Pandemic Potential”. Does SRI conduct any research that fall under these guidelines? What restrictions would be placed on future tenants as to these types of research?
Flexibility for Future Research. When asked whether the new buildings will be BSL-3 labs, Mr. Murray stated that SRI wants the flexibility for the buildings to support BSL-3 research. A BSL-3 lab typically requires powerful HVAC systems, secure containment facilities, and access controls – requirements that would be cost-prohibitive to retrofit. Thus, permitting these buildings to have this “flexibility” will virtually ensure they are used for BSL-3 research in the future. What control will Menlo Park have on research conducted at these facilities?
Mode of Release. Mr. Murray stated that community exposures from bioscience labs usually involve worker exposures (e.g., needle-sticks), not airborne releases “floating out of the building”. While worker exposure is the most common pathway, it is also true that a loss of power or a catastrophic accident could result in an airborne release. A biocontainment facility must have a continuous air supply and outgoing air filtration to prevent airborne releases. Since the plan is to decommission the cogeneration plant, how will SRI provide a non-interruptible power supply to all the laboratory buildings? Will there be backup diesel generation, and if so, how many days of fuel will be stored on site? How will SRI notify city and county officials and the community in the event of a power outage or accidental release of bioorganisms?
I recommend that the Council meet with the SRI technical staff in charge of the BSL-3 biocontainment facility to better understand the biosafety implications of this project. It would be very helpful to review the Sierra Club webinar “Planning for Life Sciences in Bay Area Communities” prior to that meeting. https://www.sierraclub.org/loma-prieta/planning-life-sciences-bay-area-communities
I understand that it would be a very tough ask for SRI to discontinue BSL-3 research at their Menlo Park campus; however, the safety of the future residents of Parkline and the larger Menlo Park community depend on your decision.
Naomi Goodman, MSPH Environmental Chemistry
Menlo Park
