August 3, 2026
Ms Katie Faulkner and Mr Bharat Singh
Planning Department
San Mateo County
Re.: San Mateo County Safety Element Update
The Sierra Club Loma Prieta Chapter’s Sustainable Land Use Committee (SLU) advocates on land use issues in San Mateo and Santa Clara Counties. In that role, we have spent a lot of time and effort researching the surge of Life Science / Biotech buildings in San Mateo County. We have also attended some of the San Mateo County Community Safety Element Meetings.
The update of the San Mateo County Safety Element provides an opportunity for the County to proactively address the public safety risks of Life Sciences/ Biotech labs.
Public safety emergency response for biotech labs impacts local and national security through pathogen containment failure, dual-use material theft, and slow local-federal coordination. When local first responders lack specialized training for hazardous biological agents, accidental or intentional releases can rapidly escalate from a local containment breach into a widespread public health crisis.
A Life Science facility is not a typical laboratory. At the higher biosafety levels BSL-3 and 4, these can contain a wide array of potentially lethal pathogens which could have catastrophic consequences in the event of a lab accident caused by human error, earthquake, flooding, fire, power grid overload or rolling black outs. The uncontrolled release of a biological agent may extend far beyond the locality, including the risk of subsequent person-to-person transmission or release into the sewer or water-system and potentially into San Francisco Bay.
Biotech labs deal with a wide range of infectious agents from benign to lethal, and thus they come with a certain level of risk. Because of this, the CDC and NIH have established four biosafety levels - BSL-1, 2, 3, & 4:
BSL-1 is the lowest safety level and presents little to no risk (minimal risk pathogens)
BSL-2 is moderate risk (salmonella, influenza)
BSL-3 is more severe risk (airborne pathogens, HIV, Covid, Plague)
BSL-4 is extreme risk (Ebola, Smallpox)
Until recently, most cities have not been aware of the four levels of risk and have approved almost all proposals regardless of the potential health and safety risk to their community.
THE DRAFT SAFETY ELEMENT SHOULD INCLUDE THE NEW BIOTECH RISKS
The Draft Safety Element addresses hazardous materials broadly but does not yet account for the distinct safety considerations of biological agents, including novel ones, their specialized waste streams, and specialized emergency response requirements. We respectfully request that you consider augmenting the following sections as follows.
In section 10. INFECTIOUS AND VECTOR-BORNE DISEASES, include discussion of the potential for accidental release of infectious agents from biolab facilities in the event of human error, accident or a natural disaster that compromises ordinary safety systems. Biological agents are invisible and their dispersal may not be immediately evident until exposure has surpassed the immediate containment zone.
In section 11. HAZARDOUS MATERIALS, include biological agents among the list of hazardous materials that may be present at biolab facilities, many of which remain proprietary and thus lack documented handling measures. Consider the need for documentation on the location of and toxins present at all biolab facilities in the event of an accidental release. Further, include requirements for the specialized transport and disposal needs of the bio-hazard waste stream.
In section 12. EMERGENCY PREPAREDNESS, RESPONSE, AND RESILIENCE, address the emergency resources that are available and should be consulted in the event of a biological agent release. Provide guidance on the agencies that would be responsible for managing such an emergency response, and the specialized training personnel need to safely handle these unique situations.
Specific Safety Element Policies and Action Items should be included to address each of the issues raised above.
INCLUDE POLICIES ON SAFE LOCATIONS FOR BIO-TECH RESEARCH FACILITIES
Locating a bio-tech research laboratory in an urbanized setting exposes a high density of sensitive receptors to safety risks. Furthermore, siting such facilities near creeks and in shoreline areas, identified as flood zones, and in high seismic and liquefaction zones, can create potential vulnerabilities for the regional Bay ecology and human health should public infrastructure be compromised and emergency protocols fail.
Several cities and towns across the United States have enacted complete bans on Biosafety Level 3 (BSL-3) and Biosafety Level 4 (BSL-4) laboratories. Municipalities usually enact these restrictions out of public safety concerns or a lack of local resources to oversee high-containment research.
Some local jurisdictions have begun to adopt enforceable standards to manage these risks. For example, San Carlos prohibits projects with biosafety level designations BSL-3 and BSL-4.1 Redwood City adopted special stricter zoning standards for biotech laboratory uses in their Downtown Mixed Use zone.2 The county should also take into consideration that the insurance industry considers these high risk facilities for jurisdictions.3
With these experiences in mind, we advocate for the exclusion of BSL-3 and BSL-4 facilities from our urbanized cities and county. We further advocate for prohibition on siting BSL-1 and BSL-2 labs near sensitive receptors such as housing, schools, senior centers, emergency shelters, medical facilities, or any of the natural hazard areas identified in this Safety Element.
The update of the San Mateo County Safety Element provides an excellent opportunity for the County to educate the public and proactively address this risk. We include our “Guidelines for BioSafety Levels in Biotech Labs” and look forward to working with you in ensuring the safety of our communities.
Respectfully,
Gita Dev, Chair, Sustainable Land Use Committee
Sierra Club Loma Prieta Chapter
Cc Ray Mueller, Chair, Emergency Services Council, San Mateo County, <rmueller@smcgov.org>
Lisa Gauthier, Supervisor District 4, San Mateo County, <SMC_SupGauthier@smcgov.org>
James Eggers, Chapter Director, Sierra Club Loma Prieta
1 San Carlos Ordinance 1597: On August 14, 2023, the City Council adopted Ordinance 1597 which prohibits research and development activities requiring Biosafety Level (BSL) 3 and 4 containment. The Ordinance permits BSL-1 and BSL-2 activities by right within a permitted life science or biotechnology business and prohibits BSL-3 and BSL-4 activities.
2 Redwood City Downtown Precise Plan amended June 26, 2023: Section 2.2.4 prohibits BSL-3 and BSL-4 in the Precise Plan Area, and implements a Use Permit Process to regulate siting and operation of BSL-1 and BSL-2 uses.
3 Biosecurity Challenges of the Global Expansion of High-Containment Biological Laboratories: Summary of a Workshop (2012) National Academies of Sciences, Engineering, and Medicine. Washington, DC: The National Academies Press. Commercial insurance and reinsurance companies evaluate the location of high-containment laboratories, BSL-3 and BSL-4, through risk underwriting, assessing proximity to population centers, flood zones, and emergency response infrastructure. Insurers analyze how close a lab is to densely populated areas, schools, or commercial hubs, high-risk flood plains, earthquake faults, liquefaction zones or hurricane-prone coastal regions due to the danger of secondary containment failure.