USW Local 8751 - District 4

Boston School Bus Drivers Union 25 Colgate Rd. Roslindale, MA 02131 Telephone (617) 524-7073 Fax (617) 524-1691 www.BostonSchoolBusUnion.org _______________________________________________________ February 20, 2013
Secretary Richard K. Sullivan, Jr. Executive Office of Energy and Environmental Affairs (EEA) Attn: MEPA Office William Gage, EEA No. 12021 100 Cambridge Street, Suite 900 Boston MA 02114

RE: Comment regarding a gross inadequacy of the Supplemental Final Environmental Impact Report (SFEIR) for the The National Emerging Infectious Diseases Laboratories (NEIDL) on Bostons Albany Street, otherwise known to the surrounding community as BUs Bioterror Lab To Whom It May Concern: I am writing representing 800 school bus drivers, members of United Steelworkers Local 8751, who transport more than 35,000 Boston students daily. During this comment period on the Supplemental Final Environmental Impact Report (SFEIR) for the The National Emerging Infectious Diseases Laboratories (NEIDL), our organization wishes to express its grave concern about the absolute lack of thought and planning in the SFEIR regarding our members and the tens of thousands of school children in the communities immediately surrounding the NEIDL. Upon learning recently that Boston University may be given permission to add Level 3 and 4 infectious diseases to its laboratory on Bostons Albany Street in Roxbury, a few blocks from the central school bus yard on the corner of Melnea Cass Boulevard and Washington Street in Roxbury, and within one mile of many schools we serve 1 that accommodate thousands of children, we downloaded the three volume SFEIR at http://www.bu.edu/neidl/resources/, with special interest in learning how the report addresses the potential impact of an infectious disease accident or release at the Albany Street laboratory on our members and the communities we serve. During a thorough search of the three volumes, our organization found no references to school children, the Boston public schools, school bus drivers, nor any material relating to the training of school bus drivers as first responders or the protocol for responding to an emergency involving a potential accident or release of infectious disease from Boston Universitys NEIDL.
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For example, located within one mile of the NEIDLs Albany Street location are the Blackstone Elementary school (.38 miles), the Hurley Elementary school (.45 miles), the Orchard Gardens K-8 school (.53 miles), the Mason Elementary school (.64 miles), the Quincy Lower (K-5) elementary school (.90 miles), the Condon Elementary school (.94 miles), the Dudley Street Neighborhood Charter School (.95 miles), along with numerous private, parochial, pre-school and day care centers.

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Our union and the First Student school bus management company, which currently holds the vendor contract for transporting all students under the care of the Boston Public Schools, are jointly responsible for conducting bi-monthly training sessions for all school bus drivers, to provide for the Massachusetts Department of Public Utilities and the Boston School Departments statutory requirements for thirteen hours of yearly training and certification of every school bus driver. As first responders for Bostons school children, our training sessions include first aid procedures, evacuations of the bus and school in the event of fire, breakdown of vehicles, facilities, utilities, and natural disasters, protocol for handling blood born pathogens, familiarity with the City of Bostons evacuation routes, and even voluntary flu vaccine clinics and flu prevention protocols during recent epidemics, among other issues. In fact, over the past three decades, school bus drivers have been among first responders in many such instances, including in the immediate vicinity of BUs NEIDL, conducting evacuations of school children during blizzards and hurricanes, fires and power outages, and numerous physical attacks by racist forces in the city (the last of which occurred in 1994, and for which, like all disasters, we continue to train and prepare.) At the most recent driver training session, held at the Freeport Street bus yard in Dorchester from 8:00 AM 1:00 PM on Saturday, February 16, 2013, union Grievance Committee Chairperson Stevan Kirschbaum a school bus driver since 1974 asked the bus companys director of driver training, Ms. Judy Lombard, about what training materials have been made available to her from First Student, Boston University, the National Institutes of Health, the Center for Disease Control, the Boston Public Health Commission, or any other agency regarding the potential and protocol for an accident or release of infectious disease from the BU NEIDL. She publicly responded that she has been provided no such material, and she neither has nor is planning to conduct any such training. For the record, neither has the USW Local 8751 nor any of its members received any such materials or training from any source. The authors of the SFEIR, under the sub-heading Other epidemiological/ecological data, do tangentially touch on the absolute need for a risk assessment to include training, planning and protocol of school personnel to deal with a potential worse case scenario. Citing a February 2007 CDC published guidance document about the need for planning for nonpharmaceutical interventions (NPI) for a potential influenza pandemic, the SFEIR authors seem to include the elemental notion that training in the communities is an essential component of risk assessment. Communities, individuals and families, employers, schools, and other organizations will be asked to plan for the use of these interventions to help limit the spread of a pandemic, prevent disease and death, lessen the impact on the economy, and keep society functioning. This interim guidance introduces a Pandemic Severity Index to characterize the severity of a pandemic, provides planning recommendations for specific interventions that communities might use for a given level of pandemic severity, and

USW Local 8751 - District 4

Boston School Bus Drivers Union 25 Colgate Rd. Roslindale, MA 02131 Telephone (617) 524-7073 Fax (617) 524-1691 www.BostonSchoolBusUnion.org _______________________________________________________ suggest (sic) when these measures should be started and how long they should be used (CDC 2007).2 That no such fundamental planning has taken place among our members and, to our knowledge, among the school communities we serve, even within a one mile radius of the NEIDL, is an outrage, an affront to our communities that proves BUs total disregard for our safety and concerns, and a primary reason for your office to reject the SFEIR, about which USW Local 8751 here submits comment for your review and action, as grossly inadequate. Sincerely,

Steven Gillis Vice President, USW Local 8751 the Boston School Bus Drivers Union

Supplemental Final Environmental Impact Report (SFEIR), Volume 3, page 271

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