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SPECIAL SECTION: CHEMICAL AND BIOLOGICAL WARFARE

Twentieth-century nonproliferation meets twenty-first-century biotechnology

 

ABSTRACT

This article explores emerging science and technology advances relevant to the 1972 Biological and Toxin Weapons Convention (BWC), and existing and needed frameworks for their identification, risk assessment, and evaluation of benefit. Threats from biological weapons continue to be a major concern as state and non-state actors have developed, used, or expressed interest in these types of weapons. International nonproliferation instruments and related efforts in health security, specifically the 2005 International Health Regulations and the 2014 Global Health Security Agenda, recognize deliberate biological incidents as one of three threats to address (the others being natural and accidental biological events). To date, these instruments and their subsequent regional and national-level implementation efforts focus primarily on pathogens and toxins as biological threat agents. Unlike the other instruments, the BWC focuses on preventing the diversion of peaceful and prophylactic uses of biology to the development, production, stockpiling, or dissemination and delivery of biological weapons. Accordingly, the BWC recognizes the importance of scientific and technological advances in enabling different actors to develop or disseminate biological agents, altering the risk profile of deliberate biological threats. To identify and discuss advances that may affect implementation of the BWC, the US National Academy of Sciences and the BWC Implementation Support Unit conducted or sponsored several activities to explore science and technologies that may be most relevant to the BWC. However, the biotechnology landscape continues to change drastically, expanding the focus of security risks beyond pathogens and toxins to include other biological data and materials, such as synthetic organisms. Factors promoting the development of biotechnology capabilities include new funders and funding models, practitioners from other disciplines leveraging the tools of biology, new nations investing in the biological sciences, and research leveraging advances in engineering, computer, data, materials, physical, and chemical sciences. These advances may reveal new capabilities that significantly alter biological nonproliferation efforts, including both new security threats and benefits to society.

Acknowledgements

We would like to thank Kathleen Vogel for inviting us to prepare this manuscript. We would like to thank Christopher Park, Robert Mikulak, and Danielle Lohman of the Department of State for their helpful discussions about the BWC. We would like to thank Jonathan Forman, formerly of the OPCW, for his helpful thoughts regarding the biological S&T advances relevant to the CWC.

Notes

1 The official title is the Protocol for the Prohibition of the Use in War of Asphyxiating, Poisonous or other Gases, and of Bacteriological Methods of Warfare.

2 United Nations, “United Nations Security Council Resolution 1540 (2004): The Role of the UN Office of Disarmament Affairs (UNODA) in support of the Committee established pursuant to Security Council Resolution 1540 (2004),” <www.un.org/disarmament/wmd/sc1540/>.

3 D. Feakes, “The Biological Weapons Convention,” Revue Scientifique et Technique-Office International Des Epizooties, Vol. 36, No. 2 (2017), <http://boutique.oie.int/extrait/20feakes621628.pdf>.

4 The CBD is an international, legally binding agreement to promote “conservation of biological diversity, the sustainable use of its components and the fair and equitable sharing of the benefits arising out of the utilization of genetic resources.” The CBD has evaluated advances such as synthetic biology and gene drives (enabled by CRISPR-based gene-editing tools), which also have been discussed within the BWC context.

5 InterAcademy Panel, “The Biological and Toxin Weapons Convention Implications of Advances in Science and Technology,” 2015; National Research Council, Trends in Science and Technology Relevant to the Biological and Toxin Weapons Convention: Summary of an International Workshop (Washington, DC: National Academies Press, 2011).

6 UNOG, “Biological Weapons Convention, 2019 Meeting of Experts, ” <www.unog.ch/80256EE600585943/(httpPages)/E8A05357EECA5490C12583BE00578053?OpenDocument>; Graham S. Pearson, “Time for Structural Changes to Make the Biological and Toxin Weapons Convention More Effective,” Global Security, Vol. 1, No. 1 (2016), pp. 23–38.

7 Jenifer Mackby, “Experts Debate Biological Weapons Challenges,” Arms Control Today, September 2018, <www.armscontrol.org/act/2018-09/news/experts-debate-biological-weapons-challenges>.

8 Several government and nongovernmental entities have held workshops. A few examples include: (a) The National Defense University held a series of workshops on emergence and convergence that included advances in biological S&T (see <https://wmdcenter.ndu.edu/Media/News/Category/13529/emerging-technologies/>). (b) The Center for Health Security published an article on the implications of life-sciences advances for biosecurity and arms control (Lane Warmbrod Kelsey, James Revill, and Nancy Connell, “Advances in Science and Technology in the Life Sciences and Their Implications for Biosecurity and Arms Control,” UNIDIR, [2020]). (c) Arizona State University holds an annual workshop on biosecurity and biotechnology (for the 2019 Biosecurity Workshop see <https://csteps.asu.edu/2019-biosecurity-workshop>).

9 Matthew P. Shearer, Michael Montague, Amanda Kobokovich, Matthew Watson, Elena Martin, Gigi Kwik Gronvall, and Nancy Connell, “Global Forum on Scientific Advances Important to the Biological & Toxin Weapons Convention,” Johns Hopkins Center for Health Security, 2019, <www.centerforhealthsecurity.org/our-work/events/2019-global-forum/200925-2019GlobalForumMtgRpt.pdf>; Tatyana Novossiolova and Maurizio Martellini, “Promoting Responsible Science and CBRN Security through Codes of Conduct and Education,” Biosafety and Health, Vol. 1, No. 2, pp. 59–64 (2019); UNODA, “UNODA Convenes a Workshop for Young Scientists to Foster Networks on Biosecurity in the Global South, ” <www.un.org/disarmament/update/unoda-convenes-a-workshop-for-young-scientists-to-foster-networks-on-biosecurity-in-the-global-south>/.

10 The concept of “dual-use dilemma” refers to research that is conducted for peaceful purposes but could be used by malicious actors to develop weapons or otherwise cause harm. This concept differs from the use of the term “dual use” in the context of export control, which distinguishes between civilian and military or national-security applications of scientific and technological advances. Although policies on the dual-use dilemma (also referred to as “dual-use life-sciences research of concern”) have been developed by the United States and other governments, a new term—“information hazard”—increasingly is being used to describe the dual-use-dilemma concept.

11 National Research Council, Biotechnology Research in an Age of Terrorism (Washington, DC: National Academies Press, 2004).

12 Yang Xue, “Developing Code of Conduct for Biology Scientists under the Framework of Convention,” presentation delivered at the BWC Meeting of Experts MX2, Geneva, August 10, 2018, <www.unog.ch/80256EDD006B8954/(httpAssets)/9219B3032A7BAD73C12582EA00294C2B/$file/Yang+Xue.pdf>; Weiwen Zhang, “Code of Conduct for Scientists in Life Sciences: Thoughts and Experience from Chinese Scientific Community,” presentation delivered at the BWC Meeting of Experts MX2, Geneva, August 10, 2018, <www.unog.ch/80256EDD006B8954/(httpAssets)/9B63503FEC6F38F5C12582EA0066659C/$file/TJU_Weiwen_2018_08_10_Request_3.pdf>.

13 World Health Organization, “Responsible Life Sciences Research for Global Health Security: A Guidance Document,” 2010, <https://apps.who.int/iris/handle/10665/70507>.

14 Engineering and Medicine National Academies of Sciences, “The U.S. National Academy of Sciences' Initiatives on Responsible Science, ” <www.nap.edu/resource/18356/responsible_science/>.

15 The InterAcademy Partnership provides opportunities for national, regional, and global member academies to work together to support the use of science in addressing societal challenges. See “About IAP,” Interacademy Partnership, n.d., <www.interacademies.org/index.php/iap/about>; InterAcademy Panel, “Doing Global Science,” 2016.

16 Stephen McAdam, “The Laboratory Biorisk Management Standard and Its Applicability under the BWC, BWC Meeting of States Parties,” presentation delivered at the BWC Meeting of States Parties, , December 3, 2008, Geneva, <www.unog.ch/80256EDD006B8954/(httpAssets)/A7CC50EFEDFF76ECC125751A004B22AA/$file/BWC_MSP_2008-Presentation-DNV.pdf> Norway 2008); United States, “Approaches to Risk and Benefit Assessment for Advances in the Life Sciences,” BWC/MSP/2019/MX.2/WP.3, July 11, 2019, <www.centerforhealthsecurity.org/our-work/pubs_archive/pubs-pdfs/2019/190729-bwc-msp-mx-2.pdf>.

17 Malcolm Dando, “Advances in Neuroscience and the Biological and Toxin Weapons Convention,” Biotechnology Research International, Vol. 11, October 7, 2010, <https://doi.org/10.4061/2011/973851>; Malcolm Dando, Neuroscience and the Future of Chemical Biological Weapons (London: Palgrave Macmillan, 2015); Daniel Gerstein and James Giordano, “Rethinking the Biological and Toxin Weapons Convention?” Health Security, Vol. 15, No. 6 (2017), <https://doi.org/10.1089/hs.2017.0082>; Graham S. Peason, “New Scientific and Technological Developments of Relevance to the Fifth Review Conference,” Bradford Disarmament Research Centre, Department of Peace Studies, University of Bradford, BTWC Review Conference Papers, No. 3, <https://bradscholars.brad.ac.uk/handle/10454/708>; United Kingdom, “Scientific and Technical Developments Relevant to the Biological Weapons Convention,” paper submitted to the United Nations Office in Geneva, n.d., <www.unog.ch/80256EDD006B8954/(httpAssets)/5B93AF9D015AD633C12571FE0049ADAF/$file/BWC-6RC-S&T-UK.pdf>.

18 Dando, Neuroscience and the Future of Chemical–Biological Weapons.

19 Biologically derived toxins fall under the BWC and CWC. In addition, any chemical that is used as a weapon or aids in the development of a chemical weapon is covered by the CWC. Molecules such as nucleic acids (the building blocks of genomes) could be considered a chemical weapon if used as such. Personal communication with Jonathan Forman, 2019)

20 John Hart, “The Convergence of Chemistry and the Life Sciences: Some Policy Implications for the Chemical Weapons Convention,” SIPRI, 2011, <www.opcw.org/sites/default/files/documents/event_photos/2011/NPS/papers/session1/John_Hart_SIPRI.pdf>; OPCW Scientific Advisory Board, Convergence of Chemisty and Biology: Report of the Scientific Advisory Board's Temporary Working Group (The Hague: OPCW, 2014).

21 Secretariat of the Convention on Biological Diversity, Synthetic Biology (Montreal, 2015).

22 National Academies of Sciences, Engineering, and Medicine, Biodefense in the Age of Synthetic Biology (Washington, DC: National Academies Press, 2018).

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24 Kathleen M. Vogel, Phantom Menace or Looming Danger? A New Framework for Assessing Bioweapons Threats (Baltimore, MD: JHU Press, 2012).

25 Ryan S. Noyce, Seth Lederman, and David H. Evans, “Construction of an Infectious Horsepox Virus Vaccine from Chemically Synthesized DNA Fragments,” PloS One, Vol. 13, No. 1 (2018).

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27 Elizabeth Finkel, “Engineered Mouse Virus Spurs Bioweapon Fears,” American Association for the Advancement of Science, January 26, 2001, <https://science.sciencemag.org/content/291/5504/585.summary>; Ronald J. Jackson, Alistair J. Ramsay, Carina D. Christensen, Sandra Beaton, Diana F. Hall, and Ian A. Ramshaw, “Expression of Mouse Interleukin-4 by a Recombinant Ectromelia Virus Suppresses Cytolytic Lymphocyte Responses and Overcomes Genetic Resistance to Mousepox,” Journal of Virology, Vol. 75, No. 3 (February 2001), pp. 1205–10.

28 Henry T. Greely, “CRISPR’d Babies: Human Germline Genome Editing in the ‘He Jiankui Affair’,” Journal of Law and the Biosciences, Vol. 6, No. 1, (2019), pp. 111–89.

29 Heidi Ledford and Ewen Callaway, “Gene Drive Mosquitoes Engineered to Fight Malaria,” Nature, November 23, 2015, <www.nature.com/news/gene-drive-mosquitoes-engineered-to-fight-malaria-1.18858>.

30 Dominique Brossard, Pam Belluck, Fred Gould, and Christopher D. Wirz, “Promises and Perils of Gene Drives: Navigating the Communication of Complex, Post-normal Science,” Proceedings of the National Academy of Sciences, Vol. 116, No. 16 (2019), pp. 7692–97; Ewen Callaway, “US Defence Agencies Grapple with Gene Drives,” Nature News, Vol. 547, No. 7664 (2017); “Ban On 'Gene Drives' Is Back on the UN's Agenda—Worrying Scientists,” (2018); James P. Collins, “Gene Drives in Our Future: Challenges of and Opportunities for Using a Self-Sustaining Technology in Pest and Vector Management,” paper presented at the BMC proceedings, 2018; Richard Schoeberl, “Gene Drives—an Emerging Terrorist Threat, ” Domestic Preparedness, December 19, 2018, <www.domesticpreparedness.com/preparedness/gene-drives-an-emerging-terrorist-threat/>.

31 Jon Cohen, “The Long Shadow of a CRISPR Scandal,” American Association for the Advancement of Science, August 2, 2019, <https://science.sciencemag.org/content/365/6452/436>; David Cyranoski and Heidi Ledford, “Genome-Edited Baby Claim Provokes International Outcry,” Nature, Vol. 563, No. 7733 (2018), <www.nature.com/articles/d41586-018-07545-0>.

32 Cary Funk and Meg Hefferon, Public Views of Gene Editing for Babies Depend on How It Would Be Used (Washington, DC: Pew Research Center , 2018).

33 Global Market Insights, “Synthetic Biology Market Revenue to Hit $55 Billion by 2025: Global Market Insights, Inc., ” Intrado, June 13, 2019, <www.globenewswire.com/news-release/2019/06/13/1868279/0/en/Synthetic-Biology-Market-revenue-to-hit-55-billion-by-2025-Global-Market-Insights-Inc.html>.

34 Michelle M. Epstein and Theo Vermeire, “Scientific Opinion on Risk Assessment of Synthetic Biology,” Trends in Biotechnology, Vol. 34, No. 8 (2016), <https://pubmed.ncbi.nlm.nih.gov/27234301/>; European Commission, “Opinion on Synthetic Biology II: Risk Assessment Methodologies and Safety Aspects," 2015, <https://ec.europa.eu/health/scientific_committees/emerging/docs/scenihr_o_048.pdf>; National Academies of Sciences, Biodefense in the Age of Synthetic Biology.

35 Matthew Warren, “Life’s Genetic Alphabet Doubled,” Nature, Vol. 566, No. 436 (2019), <https://media.nature.com/original/magazine-assets/d41586-019-00650-8/d41586-019-00650-8.pdf>; Nathaniel Scharping, “Artificial DNA Base Pair Expands Life’s Vocabulary,” Discovery, November 30, 2017, <www.discovermagazine.com/health/artificial-dna-base-pair-expands-lifes-vocabulary>; Ichiro Hirao and Michiko Kimoto, “Unnatural Base Pair Systems toward the Expansion of the Genetic Alphabet in the Central Dogma,” Proceedings of the Japan Academy, Series B Physical and Biological Sciences, Vol. 88, No. 7 (2012), pp. 345–67; Luis Ceze, Jeff Nivala, and Karin Strauss, “Molecular Digital Data Storage using DNA,” Nature Reviews, Vol. 20. (2019), pp. 456–66; Megan Molteni, “The Rise of DNA Data Storage,” Wired, June 26, 2018, <www.wired.com/story/the-rise-of-dna-data-storage/>; Sean V. Murphy and Anthony Atala, “3D Bioprinting of Tissues and Organs,” Nature Biotechnology, Vol. 32 (2014), pp. 773–85.

36 National Academy of Sciences, Safeguarding the Bioeconomy (Washington, DC: National Academy Press, 2020).

37 Damian Garde, “Senators Want to Know If HHS Money Went to Chinese Genomics Firms, ” STAT, June 12, 2019, <www.statnews.com/2019/06/12/grassley-oversight-genomics-wuxi-bgi/>; Charles E. Grassley and Marco Rubio, “Grassley, Rubio Call on HHS IG to Examine CMS Payments to Chinese-linked Companies,” June 10, 2019, <www.grassley.senate.gov/news/news-releases/grassley-rubio-call-hhs-ig-examine-cms-payments-chinese-linked-companies>; David J. Lynch, “Biotechnology: The US–China Dispute over Genetic Data, ” Financial Times, July 31, 2017, <www.ft.com/content/245a7c60-6880-11e7-9a66-93fb352ba1fe>; Lawrence A. Tabak and Roy A. Wilson, “Foreign Influences on Research Integrity,” presented during the 117th Meeting of the Advisory Committee to the Director, December 13, 2018, <https://acd.od.nih.gov/documents/presentations/12132018ForeignInfluences.pdf>.

38 Arthur Allen, “Hackers Steal 4.5m Patients' Data,” Politico, August 18, 2014, <www.politico.com/story/2014/08/chinese-hackers-steal-45-million-patients-data-110122>; BioSpace, “Wuxi Healthcare Invests in US Genomics Testmaker 23andMe, ” BioSpace, October 21, 2015, <www.biospace.com/article/releases/-b-wuxi-healthcare-b-invests-in-us-genomics-testmaker-23andme-/>; Bill Bostock, “DOJ Charges Chinese Man over 'One of the Worst Data Breaches in History' Which Took 79 Million People’s Personal Data from Anthem Health Insurers,” Business Insider, May 10, 2019, <www.businessinsider.com/chinese-hacker-stole-data-78-million-anthem-doj-say-2019-5>; Mark Kazmierczak, Ryan Ritterson, Danielle Gardner, Rocco Casagrande, Thilo Hanemann, and Daniel H. Rosen, “China’s Biotechnology Development: The Role of US and Other Foreign Engagement,” in A report prepared for the U.S.-China Economic and Security Review Commission, February 14, 2019, <www.uscc.gov/sites/default/files/Research/US-China%20Biotech%20Report.pdf>; Alex Keown, “Bay Area's Complete Genomics Loses Staff as BGI Shifts Strategy, ” BioSpace, December 2, 2015, <www.biospace.com/article/bay-area-s-complete-genomics-loses-staff-as-bgi-shifts-strategy-/>; Andrew Pollack, “Chinese Company to Acquire DNA Sequencing Firm, ” DealBook, September 17, 2012, <https://dealbook.nytimes.com/2012/09/17/chinese-company-to-acquire-dna-sequencing-firm/>; Gail Sullivan, “Chinese Hackers May Have Stolen Your Medical Records,” Washington Post, August 19, 2014, <http://www.washingtonpost.com/news/morning-mix/wp/2014/08/19/chinese-hackers-may-have-stolen-your-medical-records/>.

39 Human Rights Watch, “China: Minority Region Collects DNA from Millions: Private Information Gathered by Police, under Guise of Public Health Program, ” 2017, <www.hrw.org/news/2017/12/13/china-minority-region-collects-dna-millions>.

40 Ibid.; Maya Wang, “'Eradicating Ideological Viruses': China’s Campaign of Repression against Xinjiang’s Muslims,” Human Rights Watch, 2018, <http://www.hrw.org/sites/default/files/report_pdf/china0918_web.pdf>.

41 Natasha Khan, “American Firm, Citing Ethics Code, Won’t Sell Genetic Sequencers in Xinjiang, ” Wall Street Journal, February 20, 2019, <www.wsj.com/articles/thermo-fisher-to-stop-sales-of-genetic-sequencers-to-chinas-xinjiang-region-11550694620>; Marco Rubio, “Rubio Raises Concerns with U.S. Company over Sale of DNA Sequencing Equipment to China,” news release, February 8, 2018, <www.rubio.senate.gov/public/index.cfm/2018/2/rubio-raises-concerns-with-u-s-company-over-sale-of-dna-sequencing-equipment-to-china>; Marco Rubio, “Rubio Comments on Thermo Fisher Scientific Decision to Stop Selling DNA Sequencers,” news release, February 20, 2019, <www.rubio.senate.gov/public/index.cfm/2019/2/rubio-comments-on-thermo-fisher-s-decision-to-stop-selling-dna-sequencers>; Alim Seytoff and Paul Eckert, “Senator Questions US Firm on DNA Sequencer Sales to China, ” Radio Free Asia, February 9, 2018, <www.rfa.org/english/news/uyghur/china-dna-02092018164148.html>; Sui-Lee Wee, “China Uses DNA to Track Its People, with the Help of American Expertise,” New York Times, February 21, 2019, <http://www.nytimes.com/2019/02/21/business/china-xinjiang-uighur-dna-thermo-fisher.html>.

42 Elsa B. Kania, “Weaponizing Biotech: How China’s Military Is Preparing for a ‘New Domain of Warfare’, ” Defense One, August 14, 2019, <www.defenseone.com/ideas/2019/08/chinas-military-pursuing-biotech/159167/?oref=DefenseOneTCO>.

43 Edward You, “Safeguarding the Bioeconomy: U.S. Opportunities and Challenges,” in Testimony for the U.S.-China Economic and Security Review Commission, Federal Bureau of Investigation, Washington, DC, 2017, <www.nist.gov/system/files/documents/2018/10/19/ed_you_testimony_uscc.pdf>.

44 Mike Giglio, “China’s Spies Are on the Offensive,” The Atlantic, August 26, 2019, <www.theatlantic.com/politics/archive/2019/08/inside-us-china-espionage-war/595747/>; Office of the United States Trade Representative, Update Concerning China's Acts, Policies and Practices Related to Technology Transfer, Intellectual Property, and Innovation (Washington, DC, 2018).

45 The Foreign Investment Risk Review Modernization Act of 2018, August 13, 2018, pp. 115–232.

46 Grassley and Rubio, “Letter to the HHS Acting Inspector General.”

47 Natasha E. Bajema, Diane DiEullis, Charles Lutes, and Yong-Bee Lim, “The Digitization of Biology: Understanding the New Risks and Implications for Governance,” in Emergence & Convergence, Research paper no. 3, National Defense University, 2018 <https://wmdcenter.ndu.edu/Publications/Publication-View/Article/1569559/the-digitization-of-biology-understanding-the-new-risks-and-implications-for-go/>; Kavita M. Berger and Phyllis A. Schneck, “National and Transnational Security Implications of Asymmetric Access to and Use of Biological Data,” Frontiers in Bioengineering and Biotechnology, Vol. 7 (2019), <www.frontiersin.org/articles/10.3389/fbioe.2019.00021>; Kania, “Weaponizing Biotech.”

48 Calvin Schmidt, “Synthetic Biology Investors Are a Mix of Life Sciences and Traditional Technology Investors,” 2018, <https://synbiobeta.com/synthetic-biology-investors-are-a-mix-of-life-sciences-and-traditional-technology-investors/>; John Cumbers, “Meet Eight Tech Titans Investing in Synthetic Biology,” Forbes, September 14, 2019, <www.forbes.com/sites/johncumbers/2019/09/14/meet-the-8-tech-titans-investing-in-synthetic-biology/#7880a0fda64b>.

49 UNESCO, “UNESCO Science Report: Towards 2030,” 2015, <https://en.unesco.org/unescosciencereport>.

50 <https://experiment.com/>; Zack Miller, “The Best Platforms for Crowdfunding Science Research,” Balance Small Business, November 20, 2019, <www.thebalancesmb.com/top-sites-for-crowdfunding-scientific-research-985238>; Julien Vachelard, Thaise Gambarra-Soares, Gabriela Augustini, Pablo Riul, and Vinicius Maracaja-Coutinho, “A Guide to Scientific Crowdfunding,” PLOS Biology, Vol. 14, No. 2 (2016), e1002373.

51 DIYBio, “Local Groups,” n.d., <https://diybio.org/local/>; International Genetically Engineered Machine Foundation, “iGEM Competition,” n.d., <https://igem.org/Main_Page>.

52 Convention on the Prohibition of the Development, Production and Stockpiling of Bacteriological (Biological) and Toxin Weapons and on Their Destruction, April 10, 1972.

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54 Margaret Kosal, Nanotechnology for Chemical and Biological Defense (New York, NY: Springer, 2009).

55 Vogel, Phantom Menace or Looming Danger?

56 Human Rights Watch, “Attacks on Ghouta: Analysis of Alleged Use of Chemical Weapons in Syria,” September 10, 2013, <www.hrw.org/report/2013/09/10/attacks-ghouta/analysis-alleged-use-chemical-weapons-syria>.

57 IARPA, “Forecasting Science & Technology (Forest), ” n.d., <www.iarpa.gov/index.php/research-programs/forest>; IARPA, “Foresight and Understanding from Scientific Exposition (Fuse),” n.d., <www.iarpa.gov/index.php/research-programs/fuse>.

58 David Malakoff, “Congress Creates Two New Bodies to Tackle Foreign Influence on U.S. Research,” Science Magazine, December 10, 2019, <www.sciencemag.org/news/2019/12/congress-creates-two-new-bodies-tackle-foreign-influence-us-research>.

59 Gryphon Scientific, Risk and Benefit Analysis of Gain-of-Function Research (Takoma Park, MD, 2016).

60 Kavita M. Berger, Diane DiEullis, Corey Meyer, and Venkat Rao, “Roadmap for Implementing Biosecurity and Biodefense Policy in the United States,” Gryphon Scientific, 2017, <http://gryphonsci.wpengine.com/wp-content/uploads/2019/01/Roadmap_Roadmap-of-US-Biosecurity-and-Biodefense-Policy_2018.pdf>; DiEuliis et al., “Biodefense Policy Analysis.”

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