March 22, 2024
Honorable Mayor Taylor and Members of the City Council, via email:
Subject: Priority setting: Set safety standards for new Biotech Development
Planning Review and Entitlements of Biotech Developments to meet Health and Safety Standards
Dear Members of the City Council and Planning Commission:
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 are interested in the overall planning of our cities for the physical and environmental health of our communities.
- Bio-tech has brought us many great advantages in saving lives and food production. Bio-tech labs deal with a wide range of infectious agents from benign agents to lethal. Therefore, they come with a certain level of risk; however, these risks are not generally well understood.
- Cities need to manage the risks with a clear understanding of the differences between biosafety levels BSL 1,2 and BSL 3 & 4.
- Attached is the Sierra Club's Guidelines for Biosafety Levels (BSL) in Biotech Laboratories
- As Biotech development is being proposed in mixed use zones in cities in San Mateo and Santa Clara Counties, it must be recognized that in an urbanized setting, some of the biological infectious agents being studied at BSL-3 and 4 labs and animal research facilities do create a public health risk in the event of inevitable human error, accidents, or in disasters such as serious seismic events. Furthermore, siting of such facilities near residences, creeks and in shoreline areas, identified as flood zones, and in high seismic liquefaction zones, can create potential vulnerabilities for the regional Bay ecology and human health should public infrastructure be compromised and emergency protocols fail.
- East Coast cities, where bio-tech has had a long history, provide early guidance to facilitate development through their zoning and other mechanisms. Our guidelines are informed by them.
- We recommend your city establish a clear and effective biosafety ordinance and planning and building code and safety ordinance requirements for new Biotechnology developments, including zoning, permitting, monitoring and emergency procedures, before approving further projects.
- We further recommend that Bay Area cities prohibit high-containment BSL-3 and 4 laboratories.
San Carlos, based on belated resident concerns, has passed a ban on BSL-3&4 labs. Redwood City passed an ordinance that bans BSL 3&4 and makes BSL1&2 Conditional Use in Downtown which is a Mixed Use Plan area. Thank you for your consideration.
Respectfully Yours,
Gita Dev, FAIA, Chair
Sustainable Land Use Committee
Cc: Kyle Perata, Planning Director, Menlo Park
Deanna Chow, Community Development Director, Menlo Park
James Eggers, Executive Director, Sierra Club Loma Prieta Chapter
In light of numerous proposed biotech developments in highly urbanized locations, this document provides a starting point for identifying issues in biotech or life sciences facilities/labs using biological materials. Proper facility location and design for research or clinical labs, permitting, and operations are essential to ensuring that people working in the facility as well as the public and the environment outside the facility are protected.
- Environment and Sustainability:
- A biotech laboratory will consume five times more energyi and water per square footii than a similarly sized office building. It will also produce more single-use plastic waste and sewer waste than most other uses.
- For that reason, it is essential that biotech labs be required to be designed and constructed to meet the most efficient and effective water, energy, and waste reduction standards available.
- Health and Safety:
- A specialized biotech laboratory that deals with infectious agents is the biosafety lab (BSL). Biosafety labs may be devoted to research or to production activities and involve working with infectious materials or laboratory animals. It is essential to pay attention to the proper site location and design of these facilities, to proper protocols in using the facilities, and procedures in the event of emergencies and disasters.
- Biological safety levels (BSL) are assigned to labs and ranked from one to four, based on the agents or organisms used in the labs. Each higher level builds on the previous level, adding constraints and barriers.
- The four BSL levels were developed to protect against biohazards from a world of select agents, including bacteria, fungi, parasites, prions, rickettsial agents and viruses (the largest group).
- Studying the most infectious and hard to contain agents also means extensive security measures must be in place because of their virulence and because of their potential to escape the lab and infect the surrounding population, environment, or for use in bioterrorism. When the work involves vertebrate animals, additional precautions and safety requirements and emergency protocols are necessary.
* The Centers for Disease Control and Prevention (CDC) and the National Institutes of Health (NIH) are the main sources for biological safety information for infectious agents. The publication Biosafety in Microbiological and Biomedical Laboratories https://www.cdc.gov/labs/BMBL.html is a principal reference.
Reference: CDC and NIH—Biosafety in Microbiological and Biomedical Laboratories—6th Edition
https://www.selectagents.gov/
i EPA - Laboratories for the 21st Century - An introduction to Low-Energy Design https://www.nrel.gov/docs/fy08osti/29413.pdf
ii EPA - Water Efficiency Guide for Laboratories. https://www.nrel.gov/docs/fy05osti/36743.pdf
Lab Manager - Make Every Drop Count. https://www.labmanager.com/business-management/make-every-drop-count-4975
My Green Lab - Resources - Waste, Energy, Water. https://www.mygreenlab.org/resources.html