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Anti-terrorism, Crime and Security Act 2001, Update 1

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The following letter from Jonathan Duke-Evans at the Home Office has been circulated to many interested parties. It is a follow-up to the information provided by the Liverpool Public Analyst Laboratory a few months ago and will have implications for many who have control of a laboratory.

The letter has been slightly modified to make it more appropriate for use on the Website and for users to comunicate through the World Wide Web and e-mail.

From : Jonathan Duke-Evans
Action Against Crime and Disorder Unit
50 Queen Anne's Gate
London
SW1H 9AT
Switchboard 020 7273 4000 Fax 020 7273 2703 Direct Line 020 7273 3141
E-mail: Jonathan.Duke-Evans@HomeOffice.gsi.gov.uk
 

NEW LEGAL OBLIGATIONS AFFECTING PREMISES HOLDING DANGEROUS PATHOGENS AND TOXINS

This letter informs you of the coming into force on May 31 of new legal obligations on the occupiers of premises where certain dangerous pathogens and toxins are held. You need to consider whether you need to notify any holdings of such pathogens and toxins to the Home Office by 29 June.

2. I wrote to many recipients of this letter on 12 November last year, to inform them of new obligations which, subject to Parliamentary approval of the Anti-Terrorism, Crime and Security Bill, were to be imposed on the occupiers of premises holding stocks of certain dangerous disease strains and toxins. At the time I wrote, it was expected that the controls would come into force soon after the Bill had received Royal Assent, which it did on 14 December.
 
3. The Government, however, subsequently decided to delay implementation of these new controls for a short period, while intensive consideration was given to the possibility of excluding pathogens and toxins from the new controls in circumstances where they did not pose a substantial risk of terrorist misappropriation. That process has now been completed, and, subject to Parliament's approval of the secondary legislation, the new controls will come into force on May 31, along with a Statutory Instrument setting out the circumstances in which holdings of pathogens or toxins are exempt from these controls.
 
4. The purpose of this letter is accordingly both to explain the new obligations created by Part 7 of the Anti Terrorism, Crime and Security Act, and to set out the circumstances in which pathogens and toxins which would otherwise be covered by the controls in the Bill would be exempt. For your convenience of reference, the letter repeats where necessary information which was included in the 12 November letter

Obligations imposed by new controls
 
5. Part 7 will create the following obligations on those responsible for premises holding any of the substances listed in Annex A if none of the exemptions apply. First, it will be necessary to notify the Home Office that one or more of the substances in question is held at the premises. (I will deal with the practicalities of notification later in this letter). Second, there will be an obligation to supply the police, when they so request, with information relating to the substances held and/or the names of people with regular access to areas of the premises where the controlled substances are held. Third, the police must be admitted to the premises, following due notification by them of their intention to visit, in order to carry out security checks. Fourth, any reasonable recommendation made by the police as to security measures must be complied with (there will be an appeal process in case police recommendations are not considered reasonable). Fifth, if the Secretary of State directs that a named person should not be allowed access to areas of the premises where the controlled substances are held, the person responsible for the premises must ensure compliance. It will be an offence to fail to comply with any of these obligations.
 
6. These controls will affect premises throughout the United Kingdom (England, Scotland, Wales and Northern Ireland). Guidance is being drawn up for the police on the exercise of their new responsibilities.
 
7. If you are responsible for premises which currently hold one or more of the substances listed in Annex A, you must notify this to the Home Office within 30 days of the commencement of Part 7, i.e. by 29 June. If no such substances are held at any given premises when Part 7 comes into force, but it is subsequently decided to acquire such substances, notification must be given before the substances may be held on the premises.

Exemptions
 
8.

The Statutory Instrument of which the text is given at Annex B (Note from Web-Editor, Annex B is not included in this page. The original legislation may be accessed by following this link to the HMSO Website) creates a number of exemptions to the obligation to notify. The text of the Statutory Instrument is of course authoritative, but it may be helpful if I summarise those exemptions here :-

  • pathogens or toxins in medicinal or immunological products
  • pathogens intended to be administered to humans or animals for medicinal purposes
  • pathogens which cannot be propagated
  • pathogens which are held as part of specimens for diagnosis, provided they are disposed of as soon as possible after diagnosis
  • toxins (other than botulinum or clostridium perfringens, but including clostridium perfringens alphatoxin) held in quantities not exceeding 5 milligrams within any single secure area of the premises
  • immunotoxins
  • toxins which have not been deliberately isolated or extracted from their natural source
  • pathogens which are carried by any animal, human corpse, food, or animal feeding stuff, unless the holder knows that the infection was caused deliberately and decides nonetheless to keep them.

How to notify
 
9. If you decide that you do need to notify a holding of pathogens or toxins, you may send your notification to me by mail, fax, or e-mail, to the address/number at the head of this letter. You may wish to use the wording given at Annex C. Your notification must specify the address of the premises at which the substance or substances are held, but need not specify which substance or substances are held, nor do we need to be notified again if additional listed substances are subsequently acquired. We do, however, need to be notified if the facility ceases to hold any listed substance. There is no fee for notification. Details of notifications will be passed to the local police force, but will not otherwise be made available outside Government.
 
10. Please note that any notifications made more than 30 days after Part 7 has come into force should be made not to me but by e-mail if possible to pathogens@homeoffice.gsi.gov.uk or, failing that, to Pathogens Notifications, 6th floor West Wing, Home Office, 50 Queen Anne's Gate, London SW1H 9AT, or by fax to 020 7273 2773. Any enquiries may be addressed to the officer on duty on 020 7273 2351.
 
11.

I would like to express, on behalf of the Government, our gratitude for the many very constructive comments which we have received on these proposals from members of the research community. As a result, I believe that we have been able to keep these obligations as light as possible while still meeting the requirement to protect the public against the possible terrorist misuse of the substances. I am very grateful for the co-operation which has been shown to us.

JONATHAN DUKE-EVANS
 

ANNEX A

VIRUSES
Chikungunya virus
Congo-crimean haemorrhagic fever virus
Dengue fever virus
Eastern equine encephalitis virus
Ebola virus
Hantaan virus
Japanese encephalitis virus
Junin virus
Lassa fever virus
Lymphocytic choriomeningitis virus
Machupo virus
Marburg virus
Monkey pox virus
Rift Vally fever virus
Tick-borne encephalitis virus (Russian Spring-Summer encephalitis virus)
Variola virus
Venezuelan equine encephalitis virus
Western equine encephalitis virus
Yellow fever virus

RICKETTSIAE

Bartonella quintana (Rochalimea quintana, Rickettsia quintana)
Coxiella burnettii
Rickettsia prowazeki
Rickettsia rickettsii

BACTERIA

Bacillus anthracis
Brucella abortus
Brucella melitensis
Brucella suis
Burkholderia mallei (Pseudomonas mallei)
Burkholderia pseudomallei (Pseudomonas pseudomallei)
Chlamydophila psittaci
Clostridium botulinum
Francisella tularensis
Salmonella typhi
Shigella dysenteriae
Vibrio cholerae
Yersinia pestis

TOXINS
Aflatoxins
Botulinum toxins
Clostridium perfringens toxins
Conotoxin
Microcystin (Cyanginosin)
Ricin
Saxitoxin
Shiga toxin
Staphylococcus aureus toxins
Tetrodotoxin
Verotoxin

Notes

  1. Any reference above to a micro-organism includes :-
    1. any genetic material containing any nucleic acid sequence associated with the pathogenicity of the micro-organism; and
    2. any genetically modified organism containing any such sequence.
       
  2. Any reference above to a toxin includes -
    1. any genetic material containing any nucleic acid sequence for the coding of the toxin; and
    2. any genetically modified organism containing any such sequence.
       
  3. Any reference above to a toxin includes subunits of the toxin.


ANNEX C
 

NOTIFICATION OF HOLDING OF DANGEROUS SUBSTANCES (PART 7, ANTI-TERRORISM, CRIME, AND SECURITY ACT 2001)

Name and address of premises at which dangerous substances are held.

Name and address (if different) of person making notification

Date of notification

Before 29 June 2002, please send to :
Jonathan Duke-Evans
Home Office, 50 Queen Anne's Gate, London, SW1H 9AT.
Fax : 020 7273 2703)
e-mail : jonathan.duke-evans@homeoffice.gsi.gov.uk.

After 29 June 2002, please send to :
Pathogens Notifications
6th floor West Wing
Home Office
50 Queen Anne's Gate
London
SW1H 9AT
Fax : 020 7273 2773
e-mail : Pathogens@homeoffice.gsi.gov.


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