Using PAHPA to Address Biosecurity Threats

A letter to House and Senate health committee leaders on making sure PAHPA mitigates biosecurity risks
November 20th 2023

The following letter was delivered on November 16th to a bipartisan group of senators and representatives leading committees that are reauthorizing the Pandemic and All-Hazards Preparedness Act. IFP Biosecurity Fellow Arielle D’Souza emphasized the need for PAHPA to adequately address biosecurity, not just public health concerns.

Dear Chairman Sanders, Ranking Member Cassidy, Chairwoman McMorris Rogers, and Ranking Member Pallone, 

We applaud your bipartisan leadership in strengthening our nation’s biosecurity and emergency preparedness through the ongoing reauthorization of the Pandemic and All-Hazards Preparedness Act. 

Highlighted below are selected provisions from the Senate (S. 2333) and House (H.R. 4421) bills reported from their respective committees. These provisions are critical for ensuring our nation’s robust prevention and response capabilities. We support the inclusion of these provisions in the final package, and encourage the Senate and House to find common ground to advance those provisions that are currently present in only a single chamber’s bill.

Regarding S.2333’s Sec. 405. Gene synthesis, we believe companies must be required to ensure they are not printing DNA or RNA sequences that can create dangerous pathogens for customers who do not have legitimate research interests. As written, Sec. 405 would create a database of harmful sequences, but does not prevent companies from printing and sending them. As written, this provision may do more harm than good, as it could increase access to dual-use genetic information without restricting access to the physical products needed to create them. Instead, we suggest that Congress authorize the gene synthesis screening requirements outlined in Executive Order 14110 on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence, but apply it to both federal agencies and the private sector. This approach avoids the potential for unauthorized access to a database of harmful sequences, while mandating that federal funders and private sector actors ensure their procurements adhere to sequence screening requirements.

We thank you for your consideration of our perspective on these critical provisions.