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Assuring the Safety of the Pentagon Mail: Letter Report (2003)
Board on Radiation Effects Research (BRER)

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~ A< (: ~ Adders to thee Nation on Science, E`~ineerang, and Nledicane National Academy of Sciences National Academy of Engineering Institute of Medicine National Research Council DIVISION ON EARTH AND LIFE STUDIES Board on Radiation Effects Research December 12, 2003 Joe] B. Hucison Administrative Assistant to the Secretary of the Army 105 Army Pentagon Washington, DC 20310-0105 Dear Mr. Hudson In response to the US Army's request that the National Academies evaluate the safety of Pentagon mail, the National Research Council has constituted a committee to review current procedures of the US Post Office and Pentagon. The Committee to Evaluate the Safety of the Pentagon Mail evaluates! the efficacy of procedures implementer! to ensure the safety of the mad! ancl made recommendations for improvements. This letter describes the overall process that the committee followect and the issues it consiclerect. Specific recommendations are consiclered sensitive information and therefore are includecl in an appendix Appendix D) that is available only to the US Army. Background The anthrax cases that occurred! in the fall of 2001 resulted from spores that were sent through the US mail and demonstrated the devastation that bioterrorism can wreak on a free ant! open society (Cole 2003~. In the weeks immediately after anthrax was confirmed in October 2001, the Federal Government took steps to protect its employees and operations from attacks by biological agents an(1 relate(1 materials sent through the mails. Various branches of the government used experts to establish procedures quickly to prevent such incidents in their facilities. Members of the US scientific community were called together to discuss techniques that could be used to protect employees of the US Postal Service (USPS) and other government agencies. The initial focus was on anthrax, an easily (lisperse(1 anti extremely hazardous biological agent. A recent publication describes some of the methods that can be used to mitigate or sterilize the spores of anthrax or closely relater! species (Whitney and others 2003~. However, the nation needs to consider protection against a variety of chemical and biological agents, ant! efforts are uncler way to improve the detection, containment, mitigation, ant! decontamination of such agents (see for example Raber ant! others 2001 and 2002; Bymes, King, and Tierno 20034. 500 5th Street NW, Washington, DC 20001 Telephone (202) 334 2232 Fax (202) 334 1639 www. nationalacademies.org

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Initially, the inspection and mitigation procedures implemented for anthrax were applied to mail that had been quarantined while the procedures were being established. The USPS implemented special procedures for mail coming to federal departments in Washington, DC. The Department of Defense installed additional security procedures in the Pentagon to protect against such attacks. Other Federal agencies took similar actions. After weeks of continuous operations that eliminated the backlog of quarantined mail, the procedures were mollifies! to accommodate the daily input of mail. Those extraordinary procedures add 7-9 clays delay to normal mail delivery times for USPS mail coming into the Pentagon Building. In a move to reduce the amount of mail that must be handled by those special procedures in the aftermath of the anthrax attacks in 2001, DOD asker! their employees to redirect all personal mail received at work to their home addresses. While that has significantly reduced the mail coming to workers in the Pentagon facility it has not eliminated Class A mailings that may inclucle announcement ant! advertising mailings related to the professional activities of the recipients. After almost two years of those special operations, the Defense Post Office (DPO) asked for a National Research Council review of its mail-hancIling system. The review was prompted by the approach of renewals of contracts for some of the services involved in the operations ant! by the neec! for an overall threat and risk assessment of the procedures. The Committee The committee constituted by the Research Council for this study involves! experts in high-energy physics, chemistry, biology, public health, medicine, and risk assessment. The committee members ant! their affiliations are listen! at the ens! of this letter, along with more cletailect biographic information in Appendix A to this letter. All committee members received security clearances so that they wouic3 have access to all information necessary for an informed assessment. The statement of task agreement between the DPO and the National Academies is in Appendix B. Because of impending deadlines for contract renewals and the continued urgency surrounding the threat of bioterrorism, this study was conducted! on a short timeline with a letter report requested within 2 months of the committee's first meeting. Work Plan The committee had two 2 I/2 day meetings. The meetings were structured in accordance with guidelines that the Academies has established for open information- gathering meetings and for meetings that review sensitive or classified information not open to the public. Section ~ 5 of the Federal Advisory Committee Act (PL 92-463, 5 USC Appl) generally requires the Academies to conduct information-gathering meetings in public, but exceptions can be macle if presentations by agency of finials to the Academies would disclose matter (described in 5 USC 552(b). During the information- gathering process, the committee heard from representatives of the Pentagon administrative services and their contractors, of the USPS and their contractors, of the Office of Science and Technology Policy, of Lawrence Livermore National Laboratory, of Carnegie Mellon University, of E(lgewood Chemical Biological Center, of the US 2

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Defense Advanced Research Project Agency, and of the Department of Homelanc! Security. Committee members and Academies staff toured Pentagon facilities and US Postal Service facilities in the course of the information-gathering process. After its October 20-22, 2003, meeting the committee generates! a list of questions and organizations to which the questions were directed with the request that the committee be able to discuss the questions with appropriate knowledgeable people. On November 5, one member of the committee ant! one staff person from the Bo arc! on Radiation Effects Research visited the Pentagon again to inspect the mail-hanciling procedures while they were in progress. In its November ~ I-13, 2003, meeting the committee completed its interviews with the appropriate persons and proceeded to compile and write its report. The report was then subjected to the Academies review process before being sent to the DPO. The review process used for this report is detailed in Appendix C. Findings The Pentagon was a target of the September ~ I, 2001 attack by air. Because of increasing terrorist attacks worIc~wide and the central role of the Department of Defense (DOD) in combating terrorism, it must be considered a likely target not only of terrorist organizations but also of deranged individuals. The committee's findings were grouped into three categories: (~) overall risk assessment; (2) USPS operations; anc3 (3) DPO operations. Category (2) was necessary because, to assess ant! evaluate whether the procedures practiced by the DPO at the Pentagon were appropriate, the committee needed to look "upstream" at the procedures implemented by the USPS that determined the status of the mad! when it arrived at the Pentagon. The committee felt that the USPS had implemented extraordinary procedures after the anthrax incidents in the fall of 2001 and that the mail inspection in use at the Pentagon shouIc3 be "adcling value", i.e. reducing risk, to what the USPS was cloing if it were to continue. Therefore the committee examined the steps in the process by which the mail is separated, processed, ant! transported before arrival at the Pentagon. The committee considerecl primarily the threat and risk from attack by anthrax but also considered the protection afforcled by the procedures against a broacler array of biological agents. USPS mitigates potential anthrax and other biological agents by having mad! and packages subjected to irradiation. This irradiation process has been valiciatec! by the National Institute of Standards and Technology. It not only achieves decontamination against any anticipatect anthrax conveyed through the mail but also is likely to be equally effective against all other microbial agents ant! spores. The committee founc! that from a scientific stancipoint the radiation closes being uses! ensured that significant numbers of anthrax spores (i.e. levels considerec! to be necessary to cause inhalation anthrax infection) would not survive the irradiation process. Whereas current operations require transport of mail between USPS and a vendor for irradiation, a new facility in the Washington area will reduce transport ant! the associated delays. ~ U. S. Postal Service Emergency Preparedness Plan for Protecting Postal Employees and Postal Customers From Exposure to Biohazardous Material and for Ensuring Mail Security Against Bioterror Attacks Emergency Preparedness Plan. March 6, 2002. 3

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USPS mail anc! packages coming into the Pentagon are inspected. This process provides some acictitional risk reduction for mail received from the USPS and therefore provides a comfort level and threat recluction. The committee's recommendations were macle after exploring three clecision options relatec! to the Pentagon's procedures: continuing the Pentagon's present approach, mollifying the Pentagon's procedures, or using procedures being employecl by another Fe(leral agency. The committee found that certain procedures were unnecessary anct therefore should be cliscontinuec3, other procedures should be modified ant! improved, and new procedures should be aclded. {Other specific and detailed conclusions and recommendations, if disclosed publicly, might provide details that could lead to the circumvention of Pentagon procedures lea cling to harm to Pentagon employees or the Department of Defense. Therefore, these specific and detailed conclusions and recommendations are presented in an appendix that will not be disclosed to the generalpublic in accordance with Section 15 of the Federal Advisory Committee Act and current Justice Department guidelines interpreting the exemption provisions of the Freedom of Information Act.; . The committee also examined oroceclures that other fecleral agencies and elements . of DOD are using to ensure the safety of their mail. It examined the cooperation anc! collaboration between units involved in the total mail-handling system, beginning with the USPS and ending with the recipients of the mail. Considerations of Risk anc/ its Management The committee's recommendations were considered in a framework of risk assessment and risk management. In risk analysis, one should separate risk assessment from risk management. The former consists of the identification and quantitative characterization of threats, the likelihood of occurrence of adverse events, and their probable consequences; the latter involves decisions as to what can and should be done to mitigate the risks identified. By taking extraordinary measures, it may be possible to increase the certainty that no anthrax or other biological agents in the Pentagon's incoming mail goes undetected and non-neutralized. Extraordinary measures to address small residual risks tend to both be very expensive and often to produce little improvement in safety. When a change in a safety inspection procedure is contemplated, a risk-management decision is necessary to determine whether the change in protection warrants the extra cost (or savings). The Pentagon mail-screeninc process entails the following costs: . The cost of the screening process, including facilities, equipment, labor, and organization · The costs to operational efficiency arising from delay in incoming mail Reduced security and privacy of information contained in mail The costs and disruptions entailed in responding to false alarms Lowering of morale owing to constant physical reminders of the ongoing biological-agent threat The cost entailed by an actual biological-agent attack that, despite the screening program, is not detected before it can cause harm and disruption 4

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Other costs in the total mail system are associates! with reducing threats including the sorting, packing, ant! irradiation procedures implemented by the USPS, and costs to the receiver of mail embocliec! by its deteriorates! condition due to irradiation. The Pentagon mail-screening system has several benefits (beyond those provicled by the USPS irracliation): Increased security of Pentagon operations and their freeclom from disruption by a biological-agent attack via the mad! Increased protection of the health and safety of Pentagon personnel · Increased deterrence of biological-agent attacks on the Pentagon through lowering the likelihood that an attempt would succeed and enhancing a public image of invulnerability Increased personal vigilance on the part of employees, prompted by the visibility of institutional vigilance Increased morale of Pentagon personnel by providing a "comfort factor" that the mail is safe and that the organization is acting to protect employee welfare Any changes in the mail screening procedure will alter the various costs and expected benefits. One could make the determination that irradiation of the mail is sufficient to protect recipients from biological attack and therefore that screening of the mail is not necessary. If one determines however that irradiation alone is not sufficient to prevent attack anc! decides to screen materials that have been irradiated, then the following considerations shouicl be evaluated. A screening program that attempts to fine! rare true positives (an attack has occurrent) will have the property that most positives (most "alarms") will be false positives. Even if the probability of triggering an alarm in the absence of a true effect is very small, when hundrecls of thousands of mad! items are screened, even a very small false-positive rate will lead to a number of alarms. It is clear that an effective and efficient screening program must focus not only on detection of attacks but also on an effective program for responding to alarms a program that recognizes that most alarms will be false alarms. The follow-up needs to have a second tier of (liagnostic proceclures that can quickly verify or refute an alarm. The containment of the potential problem is important not only to minimize the consequences of a true attack, but also to avoid overreaction and undue expense in acting on a false alarm. Caution needs to be exercised in (revising an overly-rigorous screening system for detecting a biological-agent attack. There are consequences in which the most rigorous screening system can actually raise overall risks. If such a screening process creates undue inconvenience or mail delay or degradation of mail, it increases the incentive for mad! recipients to circumvent the screening. Any such circumvention may lead to greater vulnerability to attack ant! an increase in risk. Finally, the aim of the mail-screening system is to detect an attempted biological- agent attack through the Pentagon mails. Clearly, any effective system must do this well. But it is also important to recognize that the overall effectiveness of the system will also deter attacks in the first place. To cleter attacks, such systems should be publicly known to be effective. To the degree that mail attacks are perceived as unlikely to succeed, attempts will be deterred. The aim should be to provide enough public information to

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achieve creclible advertising of the effectiveness of the defense without providing enough detail to suggest means of circumventing the detection and defense system. Consic/eraVons for longer-term /mprovements to the /nspecVon anc/ /nfercepVon of Pentagon Mai/ for Hazards In the longer term, however, there are adclitional process improvements that could be made to the total system. The committee offers the following suggestions that might be considered as part of a "continuous improvement process": The Pentagon, through the DPO, should establish a strong communication link with the USPS serving the Pentagon so that it can better unclerstancT the USPS mail-irradiation and mail-handling facilities. The goal of such communication should be the optimization of the total mail-flow, inspection, and mitigation systems for USPS mail received by the recipients in the Pentagon. Regular communication is essential to the Pentagon's clevelopment of procedures to minimize the possibility of biological attack upon its facility and to ensure that such procedures are carried out in a cost-effective way. Pentagon management should review all avenues of potential biological attack on its facility. The Pentagon DPO shook! stucly and become thoroughly familiar with the work and operation of certain other DOD facilities. Pentagon management should encourage efforts across government agencies to coordinate information about the various systems used for the handing, inspection, and mitigation of fecleral mail. Some agencies may require unique systems, but many agencies may find that a common system will satisfy their neetls. Pentagon management should encourage and support USPS efforts to proceed as quickly as possible with the construction of a Washington irradiation facility complete with improved mail-han(lling equipment that will minimize hazards associates! with potential biological agents sent through the mails. The reduced transportation alone will provide a substantial savings in time ant} expense. Pentagon management should encourage ant! support cross-agency efforts to establish the best available technology for the mitigation of biological threats to the mail. The committee believes that in the long term, x-ray irradiation of mail to destroy biological agents is a preferred methoclology. Thorough studies of this irradiation technology shouIc! be camel! out promptly so that decisions regarding future facility modifications to accommodate such improvements can be macle. Pentagon management should encourage a more thorough ant! detailed} study of the entire federal mail-hanctling system with respect to biological agents, toxins, and chemical hazards; the study should recommend procedures and technology options that could be aclopted by most, if not all, federal agencies. The present Research Council study was focused on the Pentagon handing of mad! and was cane out very quickly. fOther specific and detailed conclusions and recommendations, if disclosed publicly, might provide details that could lead to the circumvention of Pentagon procedures leading to harm to Pentagon employees or the Department of Defense. Therefore, these 6

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specific and detailed conclusions and recommendations are presented in an appendix that will not be disclosed to the general public in accordance with Section 15 of the Federal Advisory Committee Act and current Justice Department guidelines interpreting the exemption provisions of the Freedom of Information Act.; References Bylines, M.E., King, D.A., and Tierno, P.M.. Nuclear, Chemical, and Biological Terrorism. Emergency Response and Public Protection. Lewis Publishers, CRC Press, Boca Raton, FE, 2003. Cole, L.A. The Anthrax Letters. A Medical Detective Story. Joseph Henry Press, Washington, D.C. 2003. Raber, E., Jin, A., Noonan, K., McGuire, R., and Kirvel, R.D.. Decontamination issues for chemical and biological warfare agents: how clean Is clean enough? International Journal of Environmental Health Research ~ I: ~ 28- ~ 4S, 200 ~ . Raber, E., Hirabayashi, J.M., Mancieri, S.P., Jin, Am., Folks, K.~., Carisen, T.M., and Estacio, P. Chemical ant! Biological Agent Incident response and decision process for civilian anclpublic sector facilities. RiskAnalysis 22:195-202, 2002. Whitney, E.A.S., Beatty, M.E., Taylor, T.H., Weyant, R., Sobel, J., Arduino, My., and D.A. Ashforcl. Inactivation of Bacillus anthracis spores. Emerging Infectious Diseases. 2003 June, available from: URE: http://www.cdc.gov/ncidocI/ElD/vol9no6/02-0377.htm. Sincerely, / ~ ~ t~ 1 ~~< Edwin P. Przybylowicz, Ph.D Chair, Committee to Evaluate the Safety of the Pentagon Mail 7

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Committee to Eva/uafe file Safety of file Pentagon Mai/ Edwin P. Przybylowicz, PhD (Chair) Senior Vice President and Director of Research (Retired), Eastman Kodak Company, Webster, NY W. Emmett Barkley, PhD Director of Laboratory Safety, Howard Hughes Meclical Institute, Chevy Chase, MD Ellen Eisen, ScD Professor of Work Environment, University of Massachusetts, Lowell and Adjunct Professor of Occupational Health, Harvard School of Public Health, Boston, MA Edwarct R. Epp, PhD Professor of Radiation Oncology (Emeritus), Harvard University, Cambridge, MA Michael R. Ladish, PhD Director of the Laboratory of Renewable Resources Engineering and Distinguished Professor of Agricultural and Biological Engineering and Biomedical Engineering, Purdue University, West Lafayette, IN Lorenz R. Rhomberg, PhD Principal of Gradient Corporation, Cambriclge, MA Andrew M. Sessler, PhD Director (Emeritus), E.O. Lawrence Berkeley National Laboratory, Berkeley, CA Bobby N. Turman, PhD Manager of the Directed Energy Applications Department Sandia National Laboratories, New Mexico, Albuquerque, NM Nationa/Academies Staff Boarc/ on Radiation Effects Research Evan Douple, PhD Boarcl Director ant! Stucly Director Rick Jostes, PhD Study Director Tina King, Project Assistant Doris E. Taylor, Staff Assistant Board on Army Science anc/ Technology . Bruce Braun, Director and liaison Air Force Science and Technology Board . Michael A. Clarke, Director and liaison Medical Fo//ow-up Agency, /nsUtute of Medicine · Rick Ercitmann, MD, MPH, Director and liaison 8

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pentagon management