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  • Writer's pictureCLTR

Response to the UK Government’s refreshed Biological Security Strategy (BSS)


Lead author: Sophie Rose (Centre for Long-Term Resilience/CLTR)

Co-authors: Cassidy Nelson (CLTR), Lalitha Sundaram (Centre for the Study of Existential Risk/CSER), Tom Hobson (CSER), Alexandra Klein (CSER) and Piers Millett (International Biosecurity and Biosafety Initiative for Science/IBBIS & University of Oxford).

 

Summary


We are pleased to see many important commitments to strengthening the UK’s capabilities for preventing, detecting and responding to biological threats in the Biological Security Strategy (BSS), published on 12 June 2023.


We particularly welcome commitments to formalise the Government’s biosecurity leadership, governance and accountability structures, to invest in the UK’s real-time biosurveillance and detection capabilities, and to lead internationally in establishing standards of best practice for responsible innovation.


We also commend the Government on allocating £1.5 billion per year to support this work, but urge the Government to continue to sustain a level of investment commensurate with the urgency and importance of implementing the BSS’ priority outcomes.


To facilitate the delivery of the Strategy’s 15 priority outcomes on such an ambitious timeline, we suggest the Government should:

  • Identify reporting milestones and specific, measurable targets for each of the priority outcomes within the Strategy.

  • Set out how it will develop thoughtful regulatory standards and practices for ensuring responsible innovation.

  • Establish mechanisms for identifying and accessing the diversity of relevant expertise needed to support the Strategy’s implementation.

  • Ensure a variety of intervention options are being evaluated and appropriately incorporated into future biological event response planning.

 

Earlier this week the UK Government published its long-awaited refresh of its Biological Security Strategy (BSS), which laid out its approach for ensuring the UK has robust capabilities to prevent, detect and respond to the full spectrum of biological threats by 2030.


The Strategy was accompanied by a press announcement highlighting that the UK is spending £1.5 billion per year to support the implementation of the BSS, however it is not clear whether this is newly allocated funding. We urge the Government to commit to sustaining a level of investment commensurate with the seriousness of these risks, which will continue to demand significant financial resources if they are to be adequately addressed.


We had the opportunity to feed into the strategy through the Cabinet Office’s Open Call for Evidence consultation process and, subsequently, a series of roundtable discussions with the Biological Security team.


We are pleased to see many important commitments in the strategy that reflect our organisations’ respective recommendations, including:

  • To formalise central leadership, and improve the governance and accountability processes underpinning biosecurity work streams within the UK Government. The BSS announces the establishment of a Lead Minister for the Strategy and the appointment of a Senior Responsible Officer (SRO) for biosecurity, to oversee implementation. These positions are now integrated into the broader UK Biological Security Governance structure (p. 58-9). We are especially delighted to see this structure include an external audit function (in the form of an external CBR [1] advisory board), in line with ‘three lines of defence’ risk management best practice and as described in our 2021 Future Proof report recommendations. The Overarching Strategic Framework also names a lead department responsible for owning and delivering on each of the 15 priority outcomes the BSS identifies.

  • To invest in the UK’s capabilities to detect and more effectively respond to the full spectrum of biological threats, including novel pathogens. The BSS outlines an ambitious vision for the UK’s National Biosurveillance Network, which will bring together all of the UK’s existing capabilities for monitoring known threats before aiming to “incorporate unbiased metagenomic approaches… with the potential to identify unknown threats.” (p. 45) We commend the Government for taking a threat-agnostic approach, which will allow for agility and resilience in the face of even novel biological threats.

  • To establish a Biosecurity Leadership Council as a forum for Government to access external expertise across industry and academia. We agree that a diverse range of expertise is required to successfully identify and manage the current and future risks associated with a rapidly transformative life sciences and biotechnology landscape, including routes of potential misuse. We are pleased to see the Government establish a mechanism for accessing relevant expertise to ensure interventions are adequate for mitigating, and proportionate to, the risks we face—as proposed in our submission to the 2019 Biosecurity and Human Health Inquiry (BHH0010).

  • To ensure their domestic biological security capabilities are regularly evaluated, tested, updated and adaptable ‘to uncertain, complex and interconnected threats.’ We agree it is immensely valuable to have relevant teams at the national and local level participate in tabletop exercises and commend the Government for committing to completing these for a range of “natural, accidental and deliberate threat [scenarios]”. Such exercises are only as useful as the mechanism for how identified vulnerabilities will be owned and addressed, so we are especially glad to see this has been highlighted as one of BSS’ key deliverables. To ensure its robustness, we would also recommend the annual forecasting exercise (pg. 26) utilise best practice methods for identifying and refining research needs, horizon- and solution-scanning, and evidence synthesis (as described in our submission to the Risk Assessment and Risk Planning Committee). This process would also benefit significantly from the involvement of experts relevant to interconnected risks (e.g. climate change as a driver of biological risk), such as OneHealth and systemic risk researchers.

We also praise the Government’s incorporation of an implementation plan for achieving the BSS’ priority outcomes, a ‘must-have’ which the Centre for Long-Term Resilience highlighted in our submissions to both the COVID-19 and Emerging Threats Inquiries, and a February opinion piece in the Financial Times. We believe that detailed implementation planning—including specific milestones and lines of accountability—will be essential to translating HMG’s vision into a reality, as we discuss further below.


The Government made several other important commitments within the BSS that we believe could play a meaningful role in mitigating the risks posed by biological threats, including:


  • To lead internationally on ‘setting and promoting strong global standards and values for responsible innovation.’ There is value in explicitly recognising that the myriad benefits of advances in life sciences and biotechnologies come with risks that need to be managed (p. 15). We commend the Government’s commitment to integrate biosecurity into the day-to-day work of both developing and using the life sciences, as well as its broader practices. Such a systemic approach will go a long way to giving greater prominence to this important issue and, if properly implemented, could offer numerous advantages for sustained engagement in the longer term and serve as an important precedent when working with global partners to strengthen regional and international capabilities. We believe this kind of international leadership is essential for preventing misuse in these areas, and that the UK could be well-placed to lead on this.

  • To develop a real-time, centralised threat-agnostic decision support tool, the Biothreats Radar, that ‘monitor[s] threats and risks as and when they appear.’ We especially commend the decision for the Biothreats Radar to incorporate ‘independent expert advisory committee analysis of biological threats and trends’, in addition to domestic biosurveillance data, global open-source information and intelligence signals.

In order to successfully deliver on the BSS commitments by 2030, we recommend the Lead Minister for Biological Security and Cabinet Office’s Biological Security Coordination Unit undertake the following activities:

  • Sustained resourcing commensurate with the urgency and importance of implementing the BSS’ objectives. It is absolutely crucial for relevant Government departments to be provided with the necessary resources to deliver on and sustain the commitments laid out in the BSS. This funding serves as an insurance policy to prevent exorbitant costs in the face of future threats—such as the estimated £376 billion (and growing) cost of COVID-19 to the UK Government (p. 14). Investment must be commensurate with the level of risk that biological threats pose: “The UK… is vulnerable to biological threats with catastrophic impacts. As devastating as COVID-19 was, there is a reasonable likelihood that another serious pandemic could occur soon, possibly within the next decade." (pg. 15).

  • Identifying a corresponding set of milestones and targets for each of the priority outcomes within the BSS. We commend the Government on providing a summary of short, medium and long-term priorities for implementation within the BSS. However, The Cabinet Office’s 2021 100 Day Mission Implementation Update (i) included an assigned Lead and (ii) articulated specific, actionable reporting and key milestones for each of the recommendations within the 100DM. We would encourage them to undertake a similar exercise for the BSS’ priority outcomes, to provide a clear way of tracking progress toward achieving their vision and suggest this be done by September 2023.

  • Set out how it will develop thoughtful regulatory standards and practices for ensuring responsible innovation. We commend the vision of the UK to position itself as a global leader for responsible innovation, especially given a rapidly shifting technology landscape (for instance, the numerous tools and capabilities being enabled by artificial intelligence). However, whilst the BSS emphasises the need to build the UK’s life sciences and biotechnology base, it provides limited detail on the process for identifying robust regulatory practices for ensuring ‘responsible innovation’ domestically—a necessary precursor for championing it beyond UK borders. We recognise that the level of coordination and expertise required to develop measures that are fit-for-purpose and responsive to developments at the forefront of science and technology is immense. As a start, we recommend (i) establishing mechanisms for identifying and leveraging relevant and diverse expertise (see below) and (ii) the pursuit of proportionate, evidence-based and actionable interventions. An example of this could be formally committing to pursuing regulatory options for DNA sequence and customer screening practices for both synthesis and benchtop device providers, both robust interventions to address the “deliberate misuse” risk of these tools (pg. 34).

  • Identify mechanisms for identifying and accessing relevant expertise to support the BSS’ implementation. Many of the priority outcomes identified in the BSS explicitly rely on engagement with qualified experts but little information is provided regarding the process of identifying them, beyond engaging with existing advisory groups (e.g. NERVTAG). In establishing this process, Government must also ensure the resulting pool is reflective of the full range of the relevant and diverse expertise needed to address cross-cutting biosecurity issues: from technical and scientific experts to risk management professionals and social sciences experts across a range of disciplines (e.g. including risk communication and mis- and dis-information experts in the development of Outcome 3’s public engagement efforts).

  • Ensure a balanced combination of technological, pharmaceutical and non-pharmaceutical interventions (NPIs) are evaluated and appropriately incorporated into biological event response planning. Despite the great successes of vaccines and other pharmaceutical measures in addressing past biological threats, there continues to be a need to develop a better evidence base for the timing and value of NPIs, particularly given the likely delay between event onset and widespread medical countermeasure availability. Since NPIs may need to be deployed in different and perhaps unprecedented ways as part of a response to future biological threats, efforts to inform response planning should prioritise understanding how best to do so.

 

The refreshed Biological Security Strategy (BSS) can be found here: https://www.gov.uk/government/publications/uk-biological-security-strategy

The Cabinet Office's press release can be found here:

 

Footnotes:

[1] CBR = chemical, biological and radiological




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