Dual Use Research of Concern – Comments on the US Government’s Proposed Policy

source: NSABB

source: NSABB

On 21 February 2013, the US Government released a proposed policy for institutional oversight of dual-use research of concern. This proposed policy was then opened to public comments, where were due yesterday. As someone who has been looking at issues of dual-use research and technology for nearly a decade, and having recently turned my attention more specifically to dual-use research in the life sciences, I felt that I needed to comment. My comments, which you’re welcome to read if you like, centered on the point that this policy will not be very effective because it places too much of the obligation to raise security concerns in the hands of the scientists doing the research. As it stands, the policy will likely be seen as a burden by the academic community, but a necessary obligation to sustain an increasingly tenuous belief in the “social contract for science”. At its core, the contract is an unwritten understanding that the government should fund science with as little oversight as possible, as this will enable free enquiry that will inevitably lead to innovation useful to the society as a whole. You can read a recent review of the problems with this vision of the relationship between science and the state in a new book out shortly called Responsible Innovation, particularly chapter 2.].

I argued that, rather than setting up the policy to fail in the same way that previous attempts at governing dual-use research have failed (e.g. the Fink Report), we should at least try something different, something that involved a recognition that securing academic freedom and the nation (and the economy!) needed an active and continuing collaborative dialogue between these communities with radically different conceptions of what needs to be secured and what counts as adequate security.

I asked other academic colleagues with a close interest in this if they were planning on submitting comments, and was somewhat surprised that several of them responded that they were not. Citing reasons of it being the middle of the semester, or that their voices would not be heard because their Washington contacts were out of date, their lack of engagement concerned me. For those of us who are engaged in, well, engaged research, I feel it is an obligation, when asked our opinion, to give it. We can criticize all we like, but when given the opportunity to have those critiques feed into the policy process, I think we should do it. I know that there are probably dozens if not hundreds of comments on this policy, and that while the government is obligated to ‘consider’ them all, there is no transparency on how this works, and the likelihood that my comments will be closely regarded. But that’s not the point. To me, doing these public comments is like voting; if you don’t vote, you can’t complain about the government you get. It’s not testifying in front of Congress, but it is being a responsible scholar.

[update: the final policy is now available] [and here’s my own version in case the government version disappears from the website.]

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