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Special articles and reports on timely nonproliferation issues by CNS staff.
Updated: Feb 1, 2010

Grading the Report Card: Assessing the WMD Commission Chairs' Biological Scoring

In the WMD Commission chairs' recent report card, released on January 26th, two grades stand out in the biological risk category.
Author: Kirk Bansak, Research Associate, CNS Washington, DC office

Posted: January 29, 2010


In 2008, former senators Bob Graham (D-FL) and Jim Talent (R-MO) chaired the bipartisan Commission on the Prevention of Weapons of Mass Destruction Proliferation and Terrorism. Based on a recommendation by the 9/11 Commission, the Graham-Talent commission was created to: (1) assess the nation's current activities and capabilities to prevent WMD proliferation and terrorism; and (2) detail concrete recommendations for addressing these threats in the future.[1]

In December of 2008, the Commission released its report entitled World at Risk. Now, a little over a year since that report was released, Graham and Talent have issued a "report card" that assesses the Obama administration's progress in implementing the report's recommendations.[2] (It should be noted that the report card was prepared by the chair and vice chair with staff support and was not endorsed by the entire Commission, which effectively disbanded in late 2008.) In the report card, the two former senators mete out grades for a range of government activities in four broad categories: biological risks, nuclear risks, government reform, and citizen and community preparedness.

The report card aims to reveal advances made by the government to protect the U.S. against WMD threats as well as point to areas where progress has been lacking so as to pressure the current administration to fill in the gaps. However, education is a two-way street, and the report card's judgments deserve their own scrutiny. In the biological risk category, two grades in particular stand out—those for progress in biodefense preparedness and strengthening the Biological Weapons Convention (BWC). However, the views expressed by the report card on these (and other) issues do not necessarily represent a consensus within the scientific community or experts interested in biosecurity.

Biodefense Preparedness

The December 2008 report recommended that the U.S. government "enhance the nation's capabilities for rapid response to prevent biological attacks from inflicting mass casualties." The Graham-Talent report card gave the U.S. government an "F" for its efforts in this area.

Criticism from Graham and Talent on this front does not come as a major surprise. They have strongly advocated for enhanced medical countermeasures, particularly vaccines, and detection capacities to respond in the wake of a biological weapon attack, which they see as both likely and not wholly preventable. Graham and Talent have conjectured that a capability for rapid response and mitigation in the biological realm (as opposed to the nuclear realm) has an important deterrent effect and therefore "may be an expansion of what is normally thought of as prevention." Moreover, even if deterrence fails, medical treatment and proper logistical response can prevent "a biological weapon...from causing mass lethality after an attack."[3]

Graham and Talent give the U.S. government a failing grade on this front largely because of a purported dearth of funds granted for the development of medical countermeasures, such as vaccines and anti-infective drugs. For example, they point to the FY2010 appropriation for the Biomedical Advanced Research and Development Authority (BARDA), the agency within the Department of Health and Human Services (HHS) that coordinates medical countermeasure development, which covered only a tenth of the cost of developing drugs and vaccines against the major biological threat agents as estimated by the Department of Homeland Security.

Graham and Talent believe that the money allocated to this activity is insufficient; however this does not necessarily mean, as report card's scoring key suggests, that "no attention or action" has been taken in this area. Thus, this failing grade, not to mention the decision to lead the entire report card with it, seems excessive given the Obama administration's continued, if somewhat diminished, emphasis on biological preparedness in general and medical countermeasure development in particular. The Obama administration has certainly not brought the biodefense R&D complex to a halt.

Graham and Talent, who also include logistical strategy and planning in their list of biothreat preparedness needs, also appear to overlook President Obama's Executive Order assigning the U.S. Postal Service responsibility for dispensing medical countermeasures in the event of a biological attack, as well as the first ever National Health Security Strategy developed by HHS.[4] These initiatives, despite their preliminary nature, should also have averted the failing grade since they are components of a concrete and ongoing effort to improve the nation's preparedness and response capacities.

Moreover, many would argue that the "F" grade exaggerates the utility of developing and stockpiling medical countermeasures, particularly vaccines, to defend against hypothetical bioterrorist threats. Since the huge expansion of the U.S. biodefense program in the aftermath of the 9/11 attacks, expert critics have argued that the U.S. government has misdirected much of its money and energy in the course of bolstering preparedness.[5] In response to the Graham-Talent report card, the Scientists Working Group on Biological and Chemical Weapons at the Center for Arms Control and Non-Proliferation released their own assessment, which asserts bluntly that "the bioterrorist threat has been greatly exaggerated." Instead of concentrating on developing vaccine countermeasures (some of which entail efficacy and safety concerns) against specific threat agents, the Scientists Working Group believes that efforts to counter bioterrorism should be integrated into the broader public health system. "Direct targeting or effort and expenditure on natural disease threats," they conclude, "would provide much greater public health benefit, and spin-offs from these programs would significantly strengthen resistance to bioterrorism."[6]

Medical countermeasures, particularly vaccines, are not a panacea. The key shortcoming of vaccines lies in the discrepancy between the large variety of potential biological threat agents (pathogens and toxins) and the agent-specific nature of vaccines.[7] To date, U.S. biodefense efforts have focused primarily on developing countermeasures to defeat the short list of pathogens and toxins that have been designated as Category A by the U.S. Centers for Disease Control and Prevention (CDC), such as the pathogens that cause the anthrax and smallpox diseases.[8] The tremendous costs involved in research, development, and procurement of a sizable stockpile of medical countermeasures means that the government must pick and choose the agents to defend against, inevitably leaving the population vulnerable to other threats. Practically speaking, the U.S. simply cannot defend against every biological threat with vaccines.

Moreover, modern biotechnology creates the possibility that pathogens could be bioengineered by skilled microbiologists to make them resistant to standard antibiotics and vaccines.[9] Of course, the ease with which countermeasure-resistant pathogens could be developed should not be overstated, particularly on the part of non-state actors. Nonetheless, the risk has existed for several decades now; the Soviet Union is alleged to have developed vaccine- and antibiotic-resistant pathogens in the 1980s, and the relevant technology continues to spread.[10]. For these reasons, Ken Alibek, a former Soviet BW scientist who defected to the United States in 1992, has suggested that we continue to develop biodefense vaccines but "keep their effectiveness in perspective." He instead advocates for therapeutic drugs that boost the immune system in a nonspecific manner as the most promising line of defense.[11] Such an approach would also reinforce the public health system as a whole.

Strengthening the BWC

Graham and Talent give the Obama Administration a B+ for "Propos[ing] a new action plan for achieving universal adherence to the Biological Weapons Convention," which was a recommendation in the December 2008 report. In contrast to the overly harsh grade given for preparedness, the BWC-related grade is probably too generous.

The Obama administration should be given credit for the comprehensiveness of its new "National Strategy for Countering Biological Threats," released on 9 December 2009 during the Annual Meeting of the States Parties to the Biological Weapons Convention in Geneva, Switzerland. Creating ways to integrate all of the tools that comprise the biological nonproliferation regime—unilateral, bilateral, and multilateral arrangements, treaties and organizations, technical and diplomatic approaches, public health and security systems—into a mutually strengthening "web of prevention" represents a true challenge. The Obama administration's strategy attempts, at least rhetorically, to weave together such a web.[12]

Yet the Obama administration's proposed measures for bolstering the cornerstone of the regime, the BWC, are strikingly weak. The strategy certainly pays lips service to the BWC, mentioning the need to revitalize the treaty and pledging to treat it as the "premiere forum for global outreach and coordination," but the strategy falls short in delivering concrete measures to ensure compliance with the treaty. Although the strategy document was introduced at the BWC States Parties meeting in Geneva, it seems more a reiteration of recommendations for allaying biological threats in general, and less a fresh roadmap for strengthening the BWC.

As Under Secretary of State Ellen Tauscher revealed in her speech to the BWC States Parties, the Obama administration agrees with its predecessor that compliance with the Convention cannot be effectively verified. During the December 2009 meeting in Geneva, Tauscher reiterated the Bush administration's position noting that "[t]he Obama administration will not seek to revive negotiations on a verification protocol to the Convention. We have carefully reviewed previous efforts to develop a verification protocol and have determined that a legally binding protocol would not achieve meaningful verification or greater security."[13] To the dismay of many arms control advocates, this announcement effectively torpedoed proposals to revive the negotiation of a BWC verification protocol, which collapsed in 2001.[14]

In this context, Graham's and Talent's grade does not come as a total surprise, given the opposition to a BWC verification protocol alluded to in the original report. In fact, the report card says "we were pleased to see the Administration's rejection of efforts to restart BWC [verification] Protocol negotiations," illustrating the tremendous weight Graham and Talent place on rejection of the protocol. While they are entitled to their own judgment on the usefulness (or uselessness) of a BWC verification protocol, it is difficult to ascertain how continued rejection of the protocol amounts to a tangible strengthening of the BWC, much less an enhanced ability to achieve universal adherence to the BWC.

In citing the Biothreats Strategy as the primary rationale for the B+ grade, the report card commends the strategy specifically for providing "national guidance for integrated actions intended to prevent biological terrorism and other significant outbreaks of infectious disease." This plaudit, while not unwarranted, seems inappropriate for this section because it overlooks the key failings of the BWC—its inability to address noncompliance concerns and its "institutional deficits," according to biological weapons nonproliferation expert and CNS Senior Fellow Jonathan Tucker.[15] In this context, granting such a high BWC-related grade seems gratuitous and a bit misguided.

Despite the complications that ultimately doomed the BWC verification protocol negotiations, some arms control advocates still believe in the desirability of a formal compliance regime. The Bush administration had some legitimate reasons for rejecting the draft protocol, including the difficulty of verifying compliance due to the pervasive dual-use nature of biotechnology, which can make it difficult for some compliant facilities to prove their peaceful intent and relatively easy for cheaters to hide illicit activities; the global diffusion of advanced biological knowledge, equipment, and technologies; the ambiguous gray areas created by biodefense research and development; and the burden of inspections on industry.[16] For these reasons, among others, the Bush administration decided that a monitoring and verification mechanism would be ineffective and create a false sense of security.

Because of these difficulties, some analysts have suggested that "bad verification [is] worse than none."[17] However, others argue that there is a middle ground between bad verification and no verification. In fact, various studies have been undertaken aimed at identifying ways to achieve such a formula through tailored monitoring provisions, scientific developments, partnerships with industry, diplomatic efforts, and a range of other tools.[18]

For example, in 2001 research undertaken by nonproliferation expert and CNS Senior Fellow Amy Smithson, who at the time led the Henry L. Stimson Center's Chemical and Biological Weapons Nonproliferation Project, sought to devise a technically sound monitoring mechanism for the BWC by opening a dialogue with academic researchers, representatives of the pharmaceutical and biotechnology industries, defense contractors, and veterans of the UN biological weapons inspections in Iraq. The resulting report concluded that the "bottom that the [BWC protocol] negotiators have much more work ahead of them if they are to achieve a meaningful, feasible BWC monitoring protocol," indicating the complexity of the task.[19] However, the report also stated that "it is incumbent upon both U.S. industry and the U.S. government to mount good faith efforts to test fully the assorted permutations of BWC monitoring technologies and strategies," pointing to the possibility of success.[20] In 2006, a Center for Strategic and International Studies conducted a survey of senior U.S. decision makers on biological weapons nonproliferation that yielded a clear majority support for BWC monitoring provisions.[21]

It is understandable that the Obama administration did not pledge to return immediately to the negotiating table for a BWC verification protocol. However, the position that the Obama administration did take with regard to the BWC is timid. The administration did not have to completely rule out the possibility of BWC verification; a more balanced and constructive position would have been to keep the protocol on ice for the near future while at the same time exploring pathways by which biological verification could become technically and politically viable—such as through scientific and technical developments, testing, and partnering with industry, all of which would likely have a number of collateral benefits. In the end, an effective verification protocol would greatly benefit the BWC and nonproliferation regime as a whole; weak verification merits opposition, but verification should not be opposed in principle.

Putting verification aside, there are other indications that the Obama administration has not truly earned its B+ in strengthening the BWC. In the January/February 2010 issue of Arms Control Today, Jonathan Tucker argues: "Overall, the specific measures in the Obama strategy that are designed to address BWC compliance concerns... appear too weak to make much of a difference." For example, he adds, the transparency measures pledged by the administration amount to little more than "token gestures [that] are unlikely to satisfy international pressures for greater transparency."[22] It is not clear what exactly Graham and Talent recognize as the concrete measures taken by the U.S. government to date that bolster adherence to the BWC.


In the World at Risk report, the Commissioners assessed that in the absence of urgent action, there is greater than a 50 percent chance that terrorists will carry out an attack somewhere in the world with a weapon of mass destruction—most likely biological—during the next five years. Graham and Talent's deep concern about this perceived threat, and their desire to bolster America's defenses against it, likely motivated them to give the Obama administration a failing grade with respect to response and mitigation. Meanwhile, their skeptical attitude towards international monitoring of compliance with the BWC seems to have motivated their overly generous grade in this area.

Graham and Talent's intentions to enhance America's security should not be questioned. Moreover, in their capacity as the co-chairs of a bipartisan, congressionally chartered Commission, Graham and Talent wield considerable influence on decision-making in Washington. However, some of their specific assessments are questionable because much of their analysis entails value judgments and speculative assumptions. Accordingly, their report card should be read and considered with a critical eye.


[1] Thomas H. Kean and Lee H. Hamilton, The 9/11 Commission Report, 22 July 2004,; Bob Graham and Jim Talent, World at Risk: The Report of the Commission on the Prevention of WMD Proliferation and Terrorism, 3 December 2008.
[2] Graham and Talent, Prevention of WMD Proliferation and Terrorism Report Card,
[3] Bob Graham and Jim Talent, "Bioterrorism: Redefining Prevention," Biosecurity and Bioterrorism, June 2009, p.126.
[4] White House Executive Order, "Medical Countermeasures Following a Biological Attack," 30 December 2009, executive-order-medical-countermeasures-following-a-biological-attack; Department of Health and Human Services, "National Health Security Strategy of the United States of America," December 2009, executive-order-medical-countermeasures-following-a-biological-attack.
[5] For example, see "An Open Letter to Elias Zerhouni," Science, 4 March 2005, p. 1409 (pre-publication copy can be accessed here:; Lynn C. Klotz and Edward J. Sylvester, "Biohazard: Why U.S. bioterror research is more dangerous than bioterrorism," Foreign Policy, 13 October 2009,; "Reducing Biological Risks to Security International Policy Recommendations for the Obama Administration," Center for Arms Control and Non-Proliferation, January 2008,
[6] Scientists Working Group on Biological and Chemical Weapons, "Biological Threats: A Matter of Balance," Center for Arms Control and Non-Proliferation, 26 January 2010, biochem/articles/biological_threats_a_matter_of_balance/.
[7] For more on the inherent advantage given to offensive biological weapons capabilities over biodefense, see Gregory Koblentz, "Chapter 1: Offense, Defense, and Deterrence," in Living Weapons: Biological Warfare and International Security, (Ithaca: Cornell University Press, 2009), pp. 9-52.
[8] Centers for Disease Control and Prevention, "Bioterrorism Agents/Diseases,"
[9] Raymond A. Zilinskas and W. Seth Carus, Possible Terrorist Use of Modern Biotechnology Techniques (Washington, D.C.: Chemical and Biological Defense Information Analysis Center, 2002).
[10] Ken Alibek and Stephen Handelman, Biohazard: The Chilling True Story of the Largest Covert Biological Weapons Program in the World—Told from Inside by the Man Who Ran It," (New York: Random House, 1999).
[11] Ibid: 288-290.
[12] National Security Council, "National Strategy for Countering Biological Threats," November 2009, National_Strategy_for_Countering_BioThreats.pdf.
[13] Under Secretary of State Ellen O. Tauscher, "Address to the Annual Meeting of the States Parties to the Biological Weapons Convention," Geneva, 9 December 2009,
[14] For a brief history of the efforts to negotiate a verification protocol for the BWC, see Jonathan B. Tucker, "Seeking Biosecurity Without Verification: The New U.S. Strategy on Biothreats," Arms Control Today, Jan/Feb 2010, pp. 9-11.
[15] Ibid: p. 13.
[16] For greater detail, see Amy E. Smithson, "Man Versus Microbe: The Negotiations to Strengthen the Biological Weapons Convention," in Biological Weapons Proliferation: Reasons for Concern, Courses of Action, Henry L. Stimson Center Report No. 24, 12 January 1998, pp. 106-126; Jonathan B.Tucker, "Verification Provisions of the Chemical Weapons Convention and Their Relevance to the Biological Weapons Convention" in Biological Weapons Proliferation: Reasons for Concern, Courses of Action, Henry L. Stimson Center Report No. 24, 12 January 1998, pp. 76-104; and Gregory Koblentz, "Chapter 2: Verification," in Living Weapons: Biological Warfare and International Security, (Ithaca: Cornell University Press, 2009), pp. 53-105.
[17] Michael Moodie, "Bolstering Compliance with the Biological Weapons Convention: Prospects for the Special Conference," Chemical Weapons Convention Bulletin, no. 25 (September 1994), p. 2.
[18] Amy E. Smithson, "House of Cards: The Pivotal Importance of a Technically Sound BWC Monitoring Protocol," Henry L. Stimson Center, May 2001; Amy E. Smithson, "Compliance through Science: U.S. Pharmaceutical Industry Experts on a Strengthened Bioweapons Nonproliferation Regime," Henry L. Stimson Center, September 2002; "The Biological Weapons Threats and Nonproliferation Options: A Survey of Senior U.S. Decision Makers and Policy Shapers," Center for Strategic and International Studies, November 2006.
[19] Smithson, "House of Cards," 2001: 85-86
[20] Ibid: 100.
[21] "The Biological Weapons Threats and Nonproliferation Options: A Survey of Senior U.S. Decision Makers and Policy Shapers," Center for Strategic and International Studies, November 2006.
[22] Tucker, "Seeking Biosecurity Without Verification: The New U.S. Strategy on Biothreats," Arms Control Today, Jan/Feb 2010: 13.

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