UC Comment Letters

This comment letter responds to the Office of Science and Technology Policy (OSTP)'s RFI on proposed changes to Dual Use Research of Concern (DURC) and Potential Pandemic Pathogen Care and Oversight (P3CO) policies. UC supports updating DURC and P3CO oversight but warns that a broad risk-based framework could overburden institutions, dilute attention from the highest-risk research, and slow important biomedical, surveillance, vaccine, and in silico work. UC recommends maintaining a clear list-based approach, combining related biosafety programs where efficient, giving federal agencies a larger role in risk assessment, preserving rapid-response pathways, and providing detailed guidance, training, examples, decision trees, and agency contacts for institutions.