An Analysis of the Origins of
the COVID-19 Pandemic
Interim Report

Senate Committee on Health Education, Labor and Pensions
Minority Oversight Staff
October 2022

Table of Contents
Foreword ....................................................................................................................................................... 3
Introduction ................................................................................................................................................... 4
Section I: Analysis of Natural Zoonotic Origins Hypothesis........................................................................ 5a.

Epidemiology of SARS-CoV-2 Outbreak Differs from Previous Natural Zoonotic Spillovers ....... 7b.

Missing Evidence of a Natural Zoonotic Spillover ......................................................................... 10c.

Problems with the Natural Zoonotic Hypothesis ............................................................................ 11

Section II: Analysis of Research-Related Incident Hypothesis .................................................................. 13a.

Coronavirus Research in Wuhan and at the Wuhan Institute of Virology ...................................... 13b.

WIV Research on SARS-related Coronaviruses with Pandemic Potential ..................................... 15c.

WIV Biosafety and Biosecurity Patents and Procurements in 2019 ............................................... 16d.

WIV Biosafety and Biosecurity Events in 2019 ............................................................................. 17

Section III: China’s Early COVID-19 Vaccine Development Versus the U.S. Operation Warp Speed .... 20
a.

U.S. Operation Warp Speed ............................................................................................................ 20b.

China’s COVID-19 Vaccine Development Program ...................................................................... 21

Section IV: Basis for Assessment that Research-Related Incident is More Likely Origin of SARS-CoV-2.................................................................................................................................................................... 23a.

Coronavirus Research at the Wuhan Institute of Virology ............................................................. 23b.

Evidence of Biosafety Failures at the WIV..................................................................................... 24c.

Management and training concerns at the WIV .............................................................................. 24d.

Anomalies in Epidemiology of SARS-COV-2 Outbreak ............................................................... 25

Conclusion .................................................................................................................................................. 262

Foreword
Over one million Americans have died from COVID-19 and tens of millions have died from thisvirus worldwide. In addition to the tragic loss of life, over the past three years we have experienced thesocial, educational, and economic costs of a global pandemic.
Last summer, Chair Murray and I announced a bipartisan Health, Education, Labor and Pensions(HELP) Committee oversight effort into the origins of SARS-CoV-2, the virus that caused the COVID-19
pandemic as part of our effort to address pandemic preparedness and response programs, and we continue
to work together on that project.
This is an interim report produced by HELP Committee Minority oversight staff. The objective wasto review publicly available, open-source information to examine the two prevailing theories of origin of
the SARS-CoV-2 virus: a natural zoonotic outbreak or a research-related incident. This Senate Health,
Education, Labor, and Pensions (HELP) Committee Minority oversight staff report is the product of that
review.
Over the last fifteen months, HELP Committee Minority oversight staff carefully reviewed several
hundred publicly available scientific studies, interviewed several dozen subject matter experts, andanalyzed previous reports and studies on the possible origins of the virus. I believe that this report provides
a significant contribution to the existing body of evidence and helps establish parameters for how future
analyses should be reviewed.
The lack of transparency and collaboration from government and public health officials in the
People’s Republic of China with respect to the origins of SARS-CoV-2 prevents reaching a more definitive
conclusion.
With COVID-19 still in our midst, it is critical that we continue international efforts to uncoveradditional information regarding the origins of this deadly virus. I hope this report will guide the World
Health Organization and other international institutions and researchers as they proceed with planned work
to continue investigating the origins of this virus. Uncovering the answers to this critical question isimperative to our national and international ability to ensure that a pandemic of this size and scope does not
happen again.
My ultimate goal with this report is to provide a clearer picture of what we know, so far, about theorigins of SARS-CoV-2 so that we can continue to work together to be better prepared to respond to future
public health threats. I believe this interim report does just that.

Richard Burr
United States Senator
Ranking Member, U.S. Senate Committee on Health, Education, Labor, and Pensions

3

Introduction
Three years after its emergence in Wuhan, exactly how SARS-CoV-2 first emerged as a respiratory
pathogen capable of sustained human-to-human transmission remains the subject of active debate.1 Experts
have put forward two dominant theories on the origins of the virus.2 The first theory is that SARS-CoV-2
is the result of a natural zoonotic spillover. 3 The second theory is that the virus infected humans as aconsequence of a research-related incident.4
Understanding the virus’s origin is essential to understanding how this outbreak happened, why
detection and reporting systems did not work as anticipated, and to better prepare for future health threats.
This report has reviewed open source, publicly available information relevant to the origins of the virus toconsolidate additional information that can be contributed to the body of work investigating the answer tothis question.
Establishing a clear picture of the likely origin of the virus has proven challenging. Since January
3, 2020, government officials in the People’s Republic of China (PRC) have prohibited sharing or
publishing any information on SARS-CoV-2 without state review and approval.5 Restrictions on SARSCoV-2 information remain in place today and, therefore, any information on SARS-CoV-2 and the COVID19 pandemic published by government officials and scientists in China must be reviewed with theserestrictions in mind.
As a result, establishing an approximate timeline for when SARS-CoV-2 first infected humans isdifficult. Government officials and public health authorities in the PRC have claimed that there were no
SARS-CoV-2 cases before early December 2019.6 However, available epidemiologic evidence strongly
suggests that SARS-CoV-2 began infecting humans in Wuhan or the surrounding area between midOctober and early to mid-November 2019.7
While precedent of previous outbreaks of human infections from contact with animals favors the
hypothesis that a natural zoonotic spillover is responsible for the origin of SARS-CoV-2, the emergence of
SARS-CoV-2 that resulted in the COVID-19 pandemic was most likely the result of a research-related
incident. This conclusion is not intended to be dispositive. The lack of transparency from government andpublic health officials in the PRC with respect to the origins of SARS-CoV-2 prevents reaching a moredefinitive conclusion. Should additional information be made publicly available, and subject to independent
verification, it is possible that these conclusions would be subject to review and reconsideration.

4

Section I
Analysis of Natural Zoonotic Origins Hypothesis
Zoonotic spillovers, in which animal diseases cross the species barrier and infect humans, are awell-known, well-documented natural phenomena.8 By some estimations, natural zoonotic spillovers are
responsible for 60 to 75 percent of emerging diseases in humans.9 Coronaviruses, to which SARS-CoV-2
belongs, are a large family of viruses that cause disease in a variety of domestic and farmed animals andhave been responsible for previous outbreaks of new diseases in humans. 10 All coronaviruses known toinfect humans are the result of natural zoonotic spillover from animals into humans.11
Two recent and prominent examples include Severe Acute Respiratory Syndrome (“SARS”) andMiddle East Respiratory Syndrome (“MERS”), both of which are caused by a coronavirus (“SARS-CoV”
and “MERS-CoV” respectively) leading to severe respiratory disease in humans. 12 Moreover, recent
infectious disease pandemics, with the exception of the 1977 Russian Flu pandemic, are believed to havenatural zoonotic origins.13

A
B

Figure 1: Example of a zoonotic spillover from bats. A: Direct spillover from bat to humans followed by human-to-humantransmission. B: Spillover from a bat to an unknown intermediate host and then to humans, followed by human-to-humantransmission.14

Natural zoonotic spillovers are a sequential process.15 In this process, an animal virus must evolvein order to become a human-adapted virus. First, a virus infects animals. Second, those infected animals
come into contact with humans (known as the human-animal interface). Third, the virus is able to infecthumans. Fourth, the virus is able to adapt to efficiently transmit between humans.16 Thus, a spillover event,in which disease is spread from animal to human, can result in one of two outcomes—either the pathogen,once transmitted from animals, is then transmitted from humans to humans, or the pathogen does not spread,
resulting in a “dead-end” spillover. In many respects, once human-to-human transmission of SARS-CoV2 was established, the onward human-to-human transmission of the virus would look similar regardless ofwhether it originated from a natural zoonotic spillover or a research-related incident.17
The natural zoonotic spillover hypothesis is a plausible explanation for how the COVID-19
pandemic started. There are a number of anomalies in the SARS-CoV-2 outbreak and the early COVID-19
pandemic compared to the emergence of past natural zoonotic spillovers, most notably the 2002-2004
SARS epidemic.

5

Figure 2: Map showing location of known SARS-related viruses most closely related to SARS-CoV-2 with five most closely related
SARS-related coronaviruses to SARS-CoV-2 within the red box.18

Based on the precedent of past natural zoonotic spillovers, if SARS-CoV-2 is the result of azoonotic spillover, it likely needed to circulate in an intermediate host to increase the virus’ chances ofbeing able to infect and replicate in humans. 19 Adaptation during circulation in an intermediate host is
believed to have played a critical role in the emergence of SARS and MERS, as well as other bat viruses,
such as hendra.20 The identity of SARS-CoV-2’s intermediate animal species remains unknown.21 If suchan intermediate animal species exists, where these intermediate species came into contact with and first
infected humans is also unknown.22 While it is likely that SARS-CoV-2 originated from a bat virus, most
likely one found in horseshoe bats residing in Southern China or Southeast Asia, it remains unknown how
SARS-CoV-2 traveled more than 1,000 miles from Southern China or Southeast Asia before emerging in
Wuhan.23 Almost three years after the COVID-19 pandemic began there is still no evidence of an animal
6

infected with SARS-CoV-2, or a closely related virus, before the first publicly reported human COVID-19
cases in Wuhan in December 2019.24
a. Epidemiology of SARS-CoV-2 Outbreak Differs from Previous Natural Zoonotic Spillovers
Most recent natural zoonotic spillovers of respiratory viruses with pandemic potential have left
behind evidence of where and how they occurred. 25 Failed inter-species transmissions, or “dead-end”
spillovers, typically leave behind serological evidence in the form of antibodies in humans and animals thatwere exposed and infected but did not effectively transmit the virus to others.26 Failed transmissions also
typically leave behind genetic evidence at the animal-human interface.27
Like interspecies transmission, human-to-human transmission also leave behind epidemiologicalevidence. The SARS epidemic saw at least five independent spillovers of the SARS virus into humans thatthen spread the virus to other humans, with other spillovers likely going unidentified and failing to cause
sustained chains of transmission.28 These spillovers occurred across multiple geographically distant live
animal markets in Guangdong Province, China over a period of several months in 2002-2003.29 Late-2003
to 2004 also saw isolated outbreaks of human SARS cases caused by additional independent spillovers ofthe virus.30 Within six months of the start of the 2002-2004 SARS epidemic, intermediate host animal
species candidates were identified, and numerous animals infected with SARS were found soon after theoutbreak was identified.31 In addition, early SARS virus samples retrieved from infected humans contained
genetic mutations that reflected its period of circulation and adaptation in palm civets, the intermediate
species.32
SARS-CoV-2’s emergence also contrasts with outbreaks of human cases of Avian Influenza H7N9
in 2013. Like the 2002-2004 SARS outbreak, H7N9 started with multiple independent introductions of thevirus into humans across multiple locations, even though the total number of human infections numberedless than 500.33 Geographically disparate, independent spillovers imply that H7N9 Avian Influenza had
circulated in bird populations for some time and across several provinces in China before the first known
human infections. This is in contrast to the lack of geographically disparate cases of early COVID-19 casesin Hubei or China.34
The occurrence of natural zoonotic spillovers is also determined in part by probability. The
frequency with which humans are exposed to an intermediate animal species infected with a zoonotic viral
agent “is likely to be an important determinant in disease emergence.” 35 This makes poorly regulated live
animal markets in China and Southeast Asia effective conduits of zoonotic diseases. 36 The crowded
conditions at these live animal markets mean that different members of multiple animal species that
ordinarily would not come into contact are placed in close proximity to each other and large numbers ofhumans. These animals are often in poor health and shed viruses.37

7

2019 Avian Influenza A H7N9

2002-2003 SARS-CoV

Figure 3: Comparison of Early Outbreaks of SARS-CoV and Avian Influenza H7N9.
Left: Map showing geographic distribution of SARS outbreak in Guangdong Province with dates of independent outbreaks of
SARS from Nov. 2002 to Jan. 2003.38
Right: Map of confirmed human cases of avian influenza A (H7N9) from Feb. 19, 2013 to April 29, 2013. 39

Figure 4: Map showing geo-temporal spread of COVID-19 in China from Dec. 31, 2019 to Feb. 11, 2020, starting only in Wuhan.40

A number of epidemiologists and virologists – and, at first, the Chinese government – have asserted
that the COVID-19 pandemic originated from a natural zoonotic transmission occurring at the Huanan
Seafood Market.41 Government officials in China have subsequently also postulated the theory that SARSCoV-2 arrived in China on the surface of imported frozen seafood or was brought into China by infected
people or animals after being created by the U.S. military. Support for these alternative theories is limited
to government-controlled publications in China and is not credible absent independent corroboration.42
Two key facts bolster the natural zoonotic origin argument. First, approximately 33 percent of theearliest known human COVID-19 cases (with symptom onset dates in mid- to late-December 2019) wereassociated with the Huanan Seafood Market in Wuhan.43 Second, a number of animal species susceptible
to SARS-CoV-2 were sold alive and in poor animal welfare conditions at the market.44
However, there is no published genetic evidence that SARS-CoV-2 was circulating in animals prior
to the start of the COVID-19 pandemic.45 Additionally, the genomes of early COVID-19 cases did not show
genetic evidence, in the form of adaptive mutations that SARS-CoV-2 recently circulated in another animal
species other than humans. 46 Moreover, the genetic similarity between the environmental samples and8human viral samples supports the likelihood that the virus found at the Huanan Seafood Market was shedby infected humans, rather than by infected animals.47
There also do not appear to have been subsequent spillovers of the virus that generated sustainedtransmission in humans, or any other independent spillovers of SARS-CoV-2, from the intermediate hostanimal(s) to humans since the pandemic started.48 It is also noteworthy that the earliest variants of SARSCoV-2 were well-adapted for human-to-human transmission.49

Huanan Seafood Market
Wuhan Institute ofVirology

Figure 5: Spatial distribution of Weibo social media platform users who used COVID-19 assistance channel, a
web application people searched when looking for flu-like symptoms, from Dec. 20, 2019 to Jan. 18, 2020,
overlaid with location of Huanan Seafood Market and Wuhan Institute of Virology’s campus in central Wuhan.
(Adapted from: Peng, Z., Wang, R., Liu, L., & Wu, H. (2020). Exploring Urban Spatial Features of COVID-19
Transmission in Wuhan Baed on Social Media Data. ISPRS International Journal of Geo-Information, 9(6), 402.
MDPI AG. Retrieved from http://dx.doi.org/10.3390/ijgi9060402).

These facts represent a significant break from the precedent of other zoonotic spillovers involving
respiratory viruses, such as MERS and SARS. Relevant past zoonotic spillovers are those involving
respiratory viruses that, like SARS-CoV-2, spread primarily through aerosols. Relatively recent spillovers
involving live animal markets in urban areas are also relevant. Isolated spillovers of viruses in rural areas
involving a small number of human infections have less precedential value, as do viruses that transmit
primarily through close physical contact or are vector-borne. Accordingly, the SARS epidemic, theemergence of MERS, and several outbreaks of avian-influenzas have greater precedential value than viruses

9like monkeypox, Zika, human immunodeficiency virus (HIV), or Ebola, because the viruses and thecircumstances of their emergence are more similar to that of SARS-CoV-2.
Early SARS-CoV-2 variants had little genetic diversity and were closely related to each other,differing by only two nucleotides out of approximately 29,900 nucleotides.50 The fact that only two earlyvariants of the virus have been identified indicates the virus had not been circulating widely or for a long
period of time, and hence had little opportunity to mutate and cause new viral variants.51 This also suggeststhat SARS-CoV-2 spilled over into humans only once or twice over an approximately two week period,
and that these one to two spillovers resulted in sustained human-to-human transmission.52 This successful
spillover also only appears to have occurred in Wuhan or closely surrounding areas.53
Understanding the epidemiology of the outbreak is difficult, as the earliest known COVID-19 cases
are unlikely to be the first humans actually infected with SARS-CoV-2.54 The earliest identified COVID19 cases, reported by PRC government officials, have a symptom onset date of December 8, 2019.55 A
majority of epidemiological modeling indicates that SARS-CoV-2 spilled over into humans between midOctober and early to mid-November 2019.56 These early Wuhan cases seeded the virus in Wuhan as SARSCoV-2 spread from person to person after the initial spillover event(s).57
The PRC has reported finding no retrospective evidence of COVID-19 cases in October or
November 2019.58 However, retrospective case searches by PRC public health authorities were limited toindividuals requiring medical treatment.59 As a result, the PRC’s retrospective case search likely missed
between 80 to 95 percent of all COVID-19 cases, which were asymptomatic or mildly symptomatic.60
Undercounting of early COVID-19 cases is also likely due to China’s restrictive case definitions which
initially required not only severe COVID-19 symptoms, but a link to the Huanan Seafood Market.61 It isestimated that during the period from mid-January to early March 2020, China’s case definitions did notaccount for approximately 200,000 COVID-19 cases.62
b. Missing Evidence of a Natural Zoonotic Spillover
Environmental samples collected between January and March 2020 at the Huanan Seafood Market
from countertops, fridges, gloves, and other surfaces tested positive for SARS-CoV-2. 63 According topresentations made to the World Health Organization (WHO) by PRC government officials and scientists
in early 2020, none of the animals at the market when it was closed, in the market’s supply chain, or in
China’s animal farming industry were infected with SARS-CoV-2.64 That would be a significant variationfrom multiple precedents from previous natural zoonotic spillovers. For example, the discovery of infectedpalm civets during the SARS epidemic, and infected chickens and other farmed birds during multiple
outbreaks of avian influenza, indicate a pattern where infected animals are expected to be present at thelocation of zoonotic spillovers and in the related supply chains. 65

10Figure 6: Animal species found to be naturally infected with SARS-CoV-2. Arrows show route of transmission. Red box highlights
mink as the only animal known to have transmitted SARS-CoV-2 back to humans.66

Cases of human-to-animal transmission of SARS-CoV-2 have led to the identification of a numberof mammal species susceptible to the virus that were sold at the Huanan Seafood Market, including mink,
foxes, and raccoon dogs. 67 Of these, mink is the only industrially farmed animal identified to havetransmitted SARS-CoV-2 from animals to humans with documented cases of farm workers being infectedwith mink-specific SARS-CoV-2 variants.68,69
China is the world’s largest producer of farmed mink, raccoon dogs, and foxes.70 Animal welfare
conditions on these farms are poor and present an ideal environment for the spread and zoonotic spilloverof SARS-CoV-2.71 Scientists expect, because of SARS-CoV-2’s ability to infect multiple species, that
SARS-CoV-2 will likely become endemic in a number of wild animal populations, including mink, deer,and foxes.72 However, PRC officials still have not reported a single SARS-CoV-2 infection in its farmed orwild mink, raccoon dog, or fox populations.73 PRC officials and scientists have also reported to the WHOthat they have not found a single instance of an animal infected with SARS-CoV-2 prior to the COVID-19
pandemic.74
c. Problems with the Natural Zoonotic Hypothesis
Based on precedent and genomics, the most likely scenario for a zoonotic origin of the COVID-19
pandemic is that SARS-CoV-2 crossed over the species barrier from an intermediate host to humans.75
However, the available evidence is also consistent, perhaps more so, with a direct bat-to-human spillover.
Both scenarios remain plausible and, in the absence of additional information, should be considered equallyvalid hypotheses.76 However, nearly three years after the COVID-19 pandemic began, critical evidence thatwould prove that the emergence of SARS-CoV-2 and resulting COVID-19 pandemic was caused by anatural zoonotic spillover is missing.

11

As described in this report, the following facts and gaps in information are reasons why the natural
zoonotic hypothesis is unlikely to explain the origins of SARS-CoV-2:


The intermediate host species for SARS-CoV-2, if one exists, remains unidentified. By comparison,
within six months of the first known human case of SARS, public health officials in China found
SARS infections in palm civets and raccoon dogs in live animal markets in Guangdong Province.77

Unlike SARS, the genomes of early COVID-19 cases from the first months of the pandemic do notshow genetic evidence of SARS-CoV-2 having circulated in another animal species other thanhumans. None of the animals tested from the Huanan Seafood Market’s supply chain, or in China’s
animal farming industry were infected with SARS-CoV-2, according to presentations by PRC
officials to the WHO.78



SARS-CoV-2’s high binding affinity for human ACE2 receptors suggests that it is possible for it
to directly infect humans without needing a period of adaptation in an intermediate host.79 Direct
spillover from a bat would explain the failure to find an intermediate host.80 While direct bat-tohuman spillover of coronaviruses has never been confirmed to cause a human outbreak, it istheoretically possible and there is circumstantial evidence suggesting it may occur under limited
specific circumstances.81



Based on the available evidence, Wuhan is the only location where SARS-CoV-2 spilled over into
humans. 82 After the unidentified source transmitted SARS-CoV-2 to humans, it stopped
transmitting SARS-CoV-2.83 This is at odds with the precedent of the 2002-2004 SARS epidemic
where infected palm civets continued to transmit the virus to humans and to raccoon dogs.84 If the
COVID-19 pandemic is the result of a zoonotic spillover from an intermediate host of SARS-CoV2, the virus would be expected to continue to circulate in the infected intermediate host population,
creating the potential for additional independent spillovers into humans and other animals.85

The low genetic diversity of the earliest SARS-CoV-2 samples suggests that the COVID-19
pandemic is most likely the result of a single successful spillover of SARS-CoV-2.86 Although thepossibility of two spillover events cannot be ruled out, both the SARS epidemic and the 2013 avian
influenza A (H7N9) outbreaks saw multiple independent spillovers of those viruses and exhibitedmuch greater genetic diversity than early SARS-CoV-2 strains.

Based on this combination of factors, the available evidence appears to be inconsistent with both
historic precedent and the scientific understanding of how natural zoonotic spillovers of respiratory viruses
like SARS-CoV-2 occur. Ultimately, without increased transparency and publicly available andreproducible evidence that addresses these missing pieces of evidence, it is difficult to support the natural
zoonotic origin hypothesis for the SARS-CoV-2 outbreak and COVID-19 pandemic.

12Section II
Analysis of Research-Related Incident Hypothesis
Research-related incidents at labs in China, the United States, and elsewhere have happened and,in some instances, resulted in limited human-to-human transmission. For example, there have been at leastsix research related incidents involving the escape of SARS-CoV from high-containment laboratories in
China (four), Taiwan (one), and Singapore (one).87 The 1977 Influenza A (H1N1) pandemic is now widely
accepted to have been the result of research-related incident, most likely a vaccine trial in the Soviet Union
or China.88 In June 2014, while investigating the unintentional exposure of one its researchers to potentially
viable anthrax during an experiment in one of its biosafety level (BSL) 3 laboratories, the U.S. Centers for
Disease Control and Prevention (CDC) discovered that a culture of non-pathogenic avian influenza wasunintentionally cross-contaminated with the highly pathogenic H5N1 strain of influenza and shipped to a
BSL3 U.S. Department of Agriculture laboratory.89 There were no personnel exposures as a result of thisevent.
In short, human errors, mechanical failure, animal bites, animal escapes, inadequate training,insufficient funding, and pressure for results can lead to an escape of virulent pathogens, which could, inturn, infect animals and humans and lead to a release of a virus from a lab.
a. Coronavirus Research in Wuhan and at the Wuhan Institute of Virology
In the aftermath of the 2002-2004 SARS epidemic, Chinese authorities emphasized research on
potential pandemic pathogens, including SARS-related coronaviruses, to develop vaccines and othermedical countermeasures with the goal of attempting to predict and prevent the next coronavirus
pandemic.90 Wuhan is a global hub of coronavirus research. The Wuhan Institute of Virology is China’s
premier coronavirus research institute. 91 Although the WIV’s coronavirus research is best documented
because of its collaborations with western scientists, multiple institutions in Wuhan study coronaviruses
including: Wuhan University, Huazhong Agricultural University, Hubei Centers for Disease Control andPrevention, Hubei Animal Centers for Disease Control and Prevention, Wuhan Centers for Disease Control
and Prevention, and the Wuhan Institute of Biological Products, a vaccine manufacturing subsidiary ofstate-owned Sinopharm.92 These institutes operate a number of biosafety level (BSL) 2, BSL3, and animal
biosafety level (ABSL) 3 laboratories. Several of the BSL3 laboratories are relatively new, having been
built only in the last five years. In all, laboratories are spread out across nine different campuses in Wuhan,with six hosting BSL3 or ABSL3 laboratories. The WIV is the only institute in Wuhan with a BSL4
laboratory.93
WIV researchers and their collaborators undertook large scale virus collection expeditions toSouthern China and Southeast Asia, where bats naturally harbor SARS-related viruses, on an annual basis
from 2004 onwards.94 During these expeditions, scientists collected bat blood, saliva, and urine samples.95
The WIV collected more than 15,000 bat-related samples around the time the pandemic began.96 Of these,
the WIV had identified more than 220 SARS-related coronaviruses, at least 100 of which have not been
made public.97

13

Figure 7: Map of BSL2, 3, and 4 (including ABSL3) laboratories in Wuhan as of December 2019.98

WIV researchers actively sampled bats in Southern China and mainland Southeast Asia where the
SARS-related coronaviruses most similar to SARS-CoV-2 have been collected and identified.99 Virusescollected from these regions are 90.7 to 96.8 percent similar overall to SARS-CoV-2.100 These include
RaTG13, which was collected by WIV researchers in Yunnan Province. 101 RaTG13 is 96.3 percent
genetically similar to SARS-CoV-2, and its existence was first made public only after the start of the
COVID-19 pandemic, in February 2020.102
Presentations given by WIV researchers in 2018 show personnel on field expeditions wearing
inadequate levels of personal protective equipment while handling bats. 103 Some personnel are
photographed wearing “thin surgical masks and rubber gloves as they work [to collect bat samples], whileothers are unmasked with bare hands.”104 By contrast, a Wuhan Chinese Centers for Disease Control andPrevention (CCDC) scientist, who also regularly conducts bat sampling expeditions, said in a 2019
documentary that “[i]t is while discovering new viruses that we [researchers] are most at risk ofinfection.”105 The CCDC scientist further stated, “[i]f our skin is exposed, it can easily come in contact withbat excrement and contaminated matter, which means this is quite risky.”106
Following field collection, samples were transported to Wuhan where they were screened for thepresence of coronaviruses.107 The WIV has two campuses, one in central Wuhan, Xiaohongshan, which
14houses BSL2 and 3 laboratories, and a second, newer campus in Wuhan’s southern suburbs, Zhengdian,which houses its BSL4 laboratory in addition to a BSL3 and multiple BSL2 laboratories. Researchers at the
WIV then conducted experiments on newly isolated and sequenced coronaviruses.108 Particular attention
was given to SARS-related coronaviruses that have the ability to bind to human ACE2 receptors.109 Theseviruses were considered by researchers at the WIV to be potential pandemic pathogens and pose a high-risk
for spillover into humans.110 Viruses were then sequenced and evaluated for their potential pandemic risk. 111
The WIV conducted genetic recombination experiments as part of its coronavirus research in both
BSL2 and BSL3 laboratories.112 The WIV also conducted transgenic humanized mice experiments to assess
the pandemic potential of SARS-related viruses.113 They also tested the efficacy of vaccines in these miceand other animal species. 114 These animal experiments generate highly-infectious aerosols that are“ubiquitous… and are difficult to detect.”115 There were concerns about conducting this type of research ina BSL2 laboratory. As of May 2019, a Chinese CCDC biosafety expert expressed concern about China’s
lack of national BSL2 regulations, recommending that “[m]anipulation of highly pathogenic
microorganisms should be performed in high level biosafety laboratories namely BSL3 or BSL4.”116
This research process takes several years, leading to a multi-year gap between discovery of a virus
and completing a paper ready for publication. For example, a virus genetically similar to SARS-CoV-2, theaforementioned RaTG13, was collected in 2013 and partially sequenced in 2016. 117 The remaining
segments of RaTG13 were sequenced in 2018 and the sequence of the virus was finally made public in
February 2020.118 In another instance, one WIV graduate student took several years to publish data that
resulted from field collection activities.119
b. WIV Research on SARS-related Coronaviruses with Pandemic Potential
By 2018, the WIV showed interest in finding SARS-related coronaviruses that used human ACE2
receptors to enter cells in order to determine whether SARS antibodies would effectively neutralize thoseviruses. 120 This research effort is described in a March 2018 grant proposal submitted to the Defense
Advanced Research Projects Agency (DARPA) by a consortium of research entities, including the WIV,
led by the U.S.-based non-governmental organization EcoHealth Alliance. The group proposed to collectand conduct genetic recombination experiments on SARS-related coronaviruses possessing specific traits
making them “high-risk” for zoonotic spillover into animals and humans.121
Notably, the proposal describes the WIV’s intent to search for SARS-related coronaviruses withpotential to bind to human ACE2 receptors and that have naturally occurring furin cleavage sites in Yunnan
Province, China.122 According to the proposal, if WIV researchers were unable to find a SARS-related virus
with these traits during sampling expeditions, they then proposed to manipulate the ACE2 receptors of
SARS-related coronaviruses to increase binding affinity to human lung tissue and to insert furin cleavage
sites at the same location where one appears in SARS-CoV-2.123 This proposal was not ultimately funded
by DARPA.
Furin cleavage sites are known to enhance virulence and increase viral replication in avian
influenza and Ebola viruses. The grant proposal is in line with research trends in the field of virology inChina. In 2015, researchers at Huazhong Agricultural University in Wuhan inserted an artificial furin15

cleavage site in Porcine Epidemic Diarrhea virus (an alpha coronavirus).124 In 2019, researchers in China
inserted a four amino acid furin cleavage site into Infectious Bronchitis coronavirus that affects
poultry.125 The WIV also received funding from PRC government agencies for research examining thespillover potential of SARS-related coronaviruses.126
In an interview with Science, Shi Zhengli, a senior scientist at the WIV and SARS-related
coronavirus expert, disclosed that her team infected civets and mice that expressed human ACE2 receptors
with chimeric SARS-related coronaviruses. 127 The results of these experiments indicated that SARS-related
bat coronaviruses could infect and cause severe illness in humanized mice.128 The WIV was later terminatedas a sub-grantee by the National Institutes of Health (NIH) for failing to produce its laboratory notes andother records relating to these other experiments.129
c. WIV Biosafety and Biosecurity Patents and Procurements in 2019
Patents by WIV researchers published in 2018, 2019, and 2020, and procurements made by the
WIV in 2019, indicate that the WIV struggled to maintain key biosafety capabilities at its high-containment
BSL3 and BSL4 laboratories.130 The following are examples of some of these patents and procurements:
On April 24, 2019, WIV researchers submitted a patent for an auxiliary exhaust fan to maintainnegative air pressure gradients in BSL3 and BSL4 high-containment laboratories.131 This auxiliary
fan was designed to prevent loss of negative pressure in the event of fan control failures, mechanicalfailures during fumigation, or human error. 132 These exhaust fans also addressed problems
fumigating and disinfecting ventilation shafts and improving penetration of disinfectants into
HEPA filters.133



On August 14, 2019, the WIV issued a procurement notice for a project involving its environmental
air disinfection system at the WIV’s campus in central Wuhan.134,135,136 The upgraded disinfection
system used vaporized hydrogen peroxide to decontaminate laboratory surfaces. 137 A gaseoushydrogen peroxide disinfection system is an effective, less corrosive means to sterilize a laboratory
than formaldehyde and other agents used by WIV researchers.138

On September 16, 2019, the WIV issued a procurement notice seeking consultation for a “central
air conditioning renovation project” at the new Zhengdian campus.139 According to the U.S. CDC:
[HVAC] system design separates potentially contaminatedlaboratory air from areas outside the laboratory by maintaining the
BSL-3/ABSL-3 areas at negative pressure to adjacent areas, by
preventing re-circulation of laboratory exhaust air to other areasof the building, and by employing special engineering controlsthat prevent the occurrence of laboratory airflow reversals to
outside the containment boundary.140

On November 19, 2019, the WIV issued a sole source procurement request for an air incinerator at
the original Xiaohongshan campus in central Wuhan.141 The contract for the procurement was to16

be issued by December 5, 2019.142 Air incinerators, though expensive to install and operate, werethe mainstay of high-containment air sterilization prior to HEPA filtration. 143 , 144 , 145 The
procurement stated that the incinerator was needed to sterilize exhaust gas from an autoclave, andthat it would be added to the exhaust pipe after existing HEPA filters outside the autoclave toincinerate all the media discharged from within.146


On December 11, 2019, WIV researchers filed a patent for a sensor to detect when biocontainmenttransfer cabinet HEPA filters had failed or were not operating correctly. 147 Experiments with
infected animals often require moving the animals from a BSL3/BSL4 laboratory to a holding
facility ABSL3/ABSL4 or transferring them from an animal holding room to a specific procedureroom.148 These animals create a variety of potentially hazardous infectious aerosols from urine,
feces, fur, and by respiration.149 The patent states, “when an accident occurs in the transportation
process, an effective monitoring device is not available for judging whether the equipment isnormal or not.”150

On November 13, 2020, WIV researchers filed a patent for a disinfectant formulation that improved
upon one used in the Institute’s high-containment laboratories. 151 The patented formulation“[r]educe[s] the corrosion effect to metal, especially stainless steel material.”152 As described in thepatent, “[l]ong-term use [of the previous disinfectant] will lead to corrosion of metal components
such as stainless steel, thereby reducing the protection of … facilities and equipment…shorten[s]its service life and cause economic losses, but also lead to the escape of highly pathogenic
microorganisms into the external environment of the laboratory, resulting in loss of life andproperty and serious social problems.”153 The patent followed a March 2018 study that described
WIV researchers using a disinfectant at a concentration more than three times higher than isrecommended by the manufacturer.154,155 The licensed U.S. manufacturer of the disinfectant statesthat “the higher … concentration, the more corrosive the solution will be.”156

d. WIV Biosafety and Biosecurity Events in 2019
With the start of operations at the WIV’s new BSL4 laboratory in late-2017 to 2018, government
officials pressured WIV researchers to “leapfrog development” by conducting cutting-edge infectious
disease research that contributed to China’s national goals for biotechnology.157 Throughout 2019, WIV
experts published on challenging biosafety and biosecurity conditions faced by high-containment
laboratories in China, including the WIV.
In May 2019, the Director of the WIV BSL4 laboratory warned that in high-containment
laboratories in China:
Maintenance cost[s] [are] generally neglected; several high-level BSLs
have insufficient operational funds for routine yet vital processes. Dueto the limited resources, some BSL-3 laboratories run on extremely
minimal operational costs or in some cases none at all…

17

Currently, most laboratories lack specialized biosafety managers andengineers. In such facilities, some of the skilled staff is composed by parttime researchers. This makes it difficult to identify and mitigate
potential safety hazards in facility and equipment operation earlyenough. Nonetheless, biosafety awareness, professional knowledge, andoperational skill training still need to be improved among laboratory
personnel. (emphasis added)158
In July 2019, China’s National People’s Congress drafted legislation, which later became law, tostrengthen the management of laboratories involved in pathogen research and improve adherence tonational standards and requirements for biosafety. It specifies that:[L]ow-level pathogenic microorganism laboratories shall not engage inpathogenic microorganism experiments that should be conducted inhigh-level pathogenic microorganism laboratories…High-level
pathogenic microorganism laboratories engaging in experimental
activities of highly pathogenic or suspected highly pathogenic
microorganisms shall be approved by the health or agriculture and ruralauthorities at or above the provincial level. For pathogenic
microorganisms that have not been discovered or have been
eliminated…relevant experimental activities shall not be carried out
without approval. (emphasis added)159
Efforts by the WIV to improve biosafety were hampered by what officials called the “strangleholdproblem,” which meant a lack of access to advanced foreign biosafety technologies and materials. 160
Leadership at the WIV emphasized during a June 2019 meeting with WIV officials that addressing the“stranglehold problem” was critical to “pushing forward the construction and… development of scienceand technology for the nation.”161 The WIV’s limited access to key foreign biosafety technologies forced
the researchers to develop biosafety methods and construct equipment to remedy shortfalls.162
In July 2019, WIV leadership led a series of internal meetings on problems of operations inmanagement at the WIV. The deputy director of the BSL4 laboratory issued a report on biocontainment
equipment shortages and the impact of meeting the research goals of the government.163 The report cited
major problems that existed in the BSL4 laboratory including “hardware and technological aspects of thelaboratory facilities” and “the management of biosafety.”164 The same report noted that the Director of theWIV urged the institute’s senior personnel to “prioritize solving the urgent problems we are currently
facing.”165
On September 12, 2019 between the hours of 2:00 and 3:00 a.m. local time,166 the WIV took down
its online depository of data on viral sequences called the Wildlife-Borne Viral Pathogen Database.167 The
database was intermittently accessible from December 2019 to February 2020, before being permanently
taken offline February 2020.168 This database was previously accessible to the public, with the exception ofa password protected section, which held unpublished sequence data accessible only to WIV personnel.169
The WIV had a collection of more than 15,000 samples from bats, from which they had identified more18

than 1,400 bat viruses, including an estimated 100 unpublished sequences of SARS-related coronaviruses– the genre of coronaviruses to which SARS-CoV-2 belongs.170 More than three years after it was firstdisabled, public access to the database has not been restored.171
On November 12, 2019, the WIV’s BSL4 laboratory team issued a report on the achievements of
the BSL4 laboratory since it began operations in 2018.172 With respect to the “stranglehold problem”, thereport states that the WIV had overcome “the three no’s” of “no equipment and technology standards, nodesign and construction teams, and no experience operating or maintaining” a high-containment
laboratory.173 The report continues to say that WIV personnel “brought into reality the ‘three haves’ of acomplete system of standards, a superior team that operates and maintains [the lab], and valuable experience
with construction.” 174 This was achieved by “reinventing” imported equipment to make “the lab
construction satisfy domestic and international standards” and making the French design of the BSL4
laboratory “conform to the requirements of Chinese construction.”175
The report also described a high-pressure work environment. “In the laboratory, they often need
to work for four consecutive hours, even extending to six hours,” the report revealed. “During this time,they cannot eat, drink, or relieve themselves. This is an extreme test of a person’s will and physicalendurance. This not only demands that research personnel possess proficient operational skills, but theymust also possess the ability to respond to various unexpected situations.”176
The November 12, 2019 report suggested a biosafety problem had occurred at the WIV sometime
before November 2019:
Owing to [the fact] that the subject of research at the P4 lab is highly
pathogenic microorganisms, inside the laboratory, once you have opened
the stored test tubes, it is just as if having opened Pandora’s Box. Theseviruses come without a shadow and leave without a trace. Although [wehave] various preventive and protective measures, it is neverthelessnecessary for lab personnel to operate very cautiously to avoid operational
errors that give rise to dangers. Every time this has happened, themembers of the Zhengdian Lab [BSL4] Party Branch have always run
to the frontline, and they have taken real action to mobilize andmotivate other research personnel. (emphasis added)177
On November 19, 2019, seven days after the BSL4 teams’ report was issued, the WIV hosted a
special training session run by a senior Chinese Academy of Sciences biosafety/biosecurity official who
relayed “important oral and written instructions” from PRC leadership in Beijing to the WIV regarding the“complex and grave situation facing [bio]security work.” 178 At the same training session, the Deputy
Director of the Office of Safety and Security at the WIV “pointed to the severe consequences that could
result from hidden safety dangers, and stressed that the rectification of hidden safety risks must be thorough,and management standards must be maintained.”179

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Section III
China’s Early COVID-19 Vaccine Development Versus the U.S. Operation Warp Speed
Once the scale of the COVID-19 pandemic became clear, governments around the world scrambled
to accelerate development of a vaccine to prevent death and severe disease from infection. In order to startvaccine development, researchers required the complete sequence of the target virus.180 The full genetic
sequence of SARS-CoV-2 was first posted to a global virus database on January 11, 2020 by a professor in
China who acted in violation of PRC government restrictions on sharing information about SARS-CoV-2.
As a consequence of his action, his laboratory was shut down for “rectification.”181
After the SARS-CoV-2’s sequence became available, vaccine developers inserted portions of theviral sequence into cells to produce the proteins that elicit an immune system response.182 The cells that
produce the proteins are called “constructs” and have to be created before vaccine development canbegin.183 After the construct is complete, the next developmental steps are preclinical animal toxicity, safety
and efficacy studies, human clinical safety and efficacy trials, and commercial scale vaccine production.184
Typically, these steps are done sequentially.185
During the COVID-19 pandemic, the urgent need for a vaccine resulted in these steps being done
concurrently, which reduced the time spent on each step from years to a few months.186 However, while
pre-clinical studies and vaccine production can be done simultaneously, each step has its own timeline tocompletion that is difficult to compress. For example, animal studies are designed to last a specific lengthof time and cannot be curtailed without compromising the resulting data.187 Similarly, the time it takes togrow the amount of vaccine needed for phase I trials is a limiting step, depending on the vaccine platform
and scale of production.
a. U.S. Operation Warp Speed
The companies with candidate vaccines that would later be funded and supported by Operation
Warp Speed in the United States all started vaccine development work on January 11, 2020 after the public
release of the first SARS-CoV-2 sequence.188 While mRNA vaccine candidates were able to design theirvaccine construct in two days, because mRNA vaccines only need the coronavirus' genetic sequence tomake a vaccine and no virus has to be cultivated in labs, traditional vaccine platforms take longer.189
The fastest of the Operation Warp Speed vaccine candidates to enter phase I human clinical trials
among the non-mRNA vaccines was AstraZenca-Oxford’s vaccine, ChAdOx1.190 The AstraZeneca-Oxford
team leveraged an existing vaccine construct and extensive experience with it to advance their candidate
into phase I human clinical trials in an unprecedented 103 days.191 Johnson & Johnson’s vaccine candidate,
Ad26, went from sequence to phase I clinical trials in 185 days.192 As with AstraZeneca-Oxford, Johnson& Johnson was able to modify an existing construct it had developed for Ebola, as well as extensive
institutional experience in vaccine development.193 Both Ad26 and ChAdOx1 were adenovirus vaccines, inwhich a weakened version of the virus that cannot replicate is used to stimulate an immune reaction.194
Operation Warp Speed brought the first COVID-19 vaccines from sequence publication toregulatory approval in approximately eight months; “[o]ther medical miracles have been achieved, but few
20

with the speed and success of developing the Covid-19 vaccines.”195 Operation Warp Speed accelerated
development of COVID-19 vaccines by coordinating with the U.S. Food and Drug Administration (FDA)and Centers for Disease Control and Prevention, providing technical assistance, breaking through supply
chain and manufacturing bottlenecks with the Defense Production Act, and de-risking vaccine development
through guaranteed purchase agreements.196 Vaccine developers ran clinical trials concurrently and on an
accelerated timeline. The lessons learned from Operation Warp Speed have been widely shared, studied,and publicized, so it can serve as a model for how to quickly mobilize the government and private sector in
response to an emergency.197
b. China’s COVID-19 Vaccine Development Program

China also initiated a COVID-19 vaccine development with at least four research teams involved.198
China did not initially have a mRNA vaccine candidate.199 Two of these research teams were from thePeople’s Liberation Army’s Academy of Military Medical Sciences (AMMS), with the others from the
Chinese Academy of Sciences (CAS) and the Chinese Centers for Disease Control and Prevention(CCDC).200 The two AMMS teams reached notable early milestones in COVID-19 vaccine development.
One AMMS team, led by Major General Chen Wei, using the same adenovirus vaccine platform as
AstraZeneca-Oxford and Johnson & Johnson, went from sequence publication on January 11, 2020 to phase
I human clinical trials on March 18, 2020, a span of only 67 days.201

Figure 8: Comparison of Adenovirus Platform Timelines. Operation Warp Speed Vaccines: Johnson & Johnson’s Ad26 andAstraZeneca-Oxford’s ChADOx1 compared to Chen-AMMS’s SV8000

The second AMMS team, led by Brigadier General Yusen Zhou, was the first to patent a COVID19 vaccine on February 24, 2020. 202 The Zhou AMMS team’s patent included data from a mouse
experiment showing that the vaccine construct neutralized SARS-CoV-2 infections.203 Other researchers in
China working with the same vaccine platform took between three to four months to develop their candidate21

vaccine.204 The Zhou AMMS COVID-19 vaccine candidate does not appear to have advanced into phase I
human clinical trials.205 The Chen AMMS COVID-19 vaccine is commercially produced by CanSino.206
Given Operation Warp Speed’s success, it is unusual that the two AMMS COVID-19 vaccine
development teams were able to reach early milestones in vaccine development even more quickly. The
Chen AMMS team beat AstraZeneca-Oxford to phase I clinical trials by 38 days. The Zhou AMMS teambuilt and validated the effectiveness of its COVID-19 candidate vaccine 44 days after the sequence of
SARS-CoV-2 was released. The extremely accelerated vaccines development timelines achieved by the
AMMS teams pose the following two outstanding questions:

What additional steps, processes, or novel techniques did AMMS researchers take that
advanced the development of their vaccine faster than the Operation Warp Speed timeline?



If no additional steps were taken to speed up the development timeline, when did
researchers in China have access to the genomic sequence? Was it before January 11, 2020?
If so, how far in advance of January 11, 2020?

22

Section IV
Basis for Assessment that Research-Related Incident is More Likely Origin of SARS-CoV-2
Nearly three years after the COVID-19 pandemic began, substantial evidence demonstrating that
the COVID-19 pandemic was the result of a research-related incident has emerged. A research-related
incident is consistent with the early epidemiology showing rapid spread of the virus in Wuhan, with theearliest calls for assistance being located in the near the WIV’s original campus in central Wuhan.207 It also
explains the low genetic diversity of the earliest known SARS-CoV-2 human infections in Wuhan, because
the likely index case, would be an infected researcher, is the likely primary source of the virus in Wuhan.208
A research-related incident also explains the failure to find an intermediate host as well as the failure tofind any animal infections pre-dating human COVID-19 cases.209
Although the WIV’s coronavirus research is best documented because of its collaborations withwestern scientists, multiple institutions in Wuhan study coronaviruses including: Wuhan University,
Huazhong Agricultural University, Hubei Centers for Disease Control and Prevention, Hubei Animal
Centers for Disease Control and Prevention, Wuhan Centers for Disease Control and Prevention, and the
Wuhan Institute of Biological Products, a vaccine manufacturing subsidiary of state-owned Sinopharm.
a. Coronavirus Research at the Wuhan Institute of Virology
The WIV is an epicenter of advanced coronavirus research that was designed to predict and prevent
future pandemics by collecting, characterizing, and experimenting on “high-risk” coronavirus with thepotential to spill over into humans:In the aftermath of the 2002-2004 SARS epidemic, WIV researchers undertook annual virus
collection expeditions to Southern China and Southeast Asia, where bats naturally harbor SARSrelated viruses, from 2004 onward.210



WIV researchers actively sampled bats in Southern China and Southeast Asia where the SARSrelated coronaviruses most similar to SARS-CoV-2 have been collected and identified.211



The WIV had collected more than 15,000 samples from bats, from which they had identified morethan 1,400 bat viruses, including an estimated 100 unpublished sequences of SARS-related
coronaviruses – the genre of coronaviruses to which SARS-CoV-2 belongs. 212 The database
containing the sequences of viruses collected by the WIV, including unpublished SARS-related
coronaviruses, was taken offline starting in September 2019.



Following field collection, samples were transported to Wuhan, where they were screened for thepresence of coronaviruses.213 WIV researchers performed animal and human cell-related researchusing recombinant genetic techniques with the express goal of discovering human adapted SARSlike chimeric viruses. The WIV conducted these experiments in BSL2 and BSL3 laboratories.

23

Senior coronavirus researcher Shi Zhengli disclosed that in 2018-2020, her team infected civets
and humanized mice that expressed human ACE2 receptors with chimeric SARS-related
coronaviruses.214 The results of these experiments have never been published.

The EcoHealth Alliance NIH grants and DARPA grant proposals, in partnership with the WIV,
sought to collect and conduct genetic recombination experiments on SARS-related coronaviruses
with specific traits that made those viruses a “high-risk” for zoonotic spillover into animals andhumans.215 SARS-CoV-2 shares many of the traits these researchers were interested in finding in
SARS-related coronaviruses or interested in engineering such traits if they were not foundnaturally.

b. Evidence of Biosafety Failures at the WIVWIV patents and procurements suggest that the WIV experienced persistent biosafety problems
relevant to the containment of an aerosolized respiratory virus like SARS-CoV-2.







April 24, 2019:
August 14, 2019:
September 16, 2019:
November 19, 2019:
December 11, 2019:
November 13, 2020:

Auxiliary exhaust patent
Environmental air disinfection system procurement
Central air conditioning
Sole source procurement for air incinerator
Biocontainment transfer cabinet HEPA filter failure patent
Disinfectant formulation patentc. Management and training concerns at the WIV
Academic articles, reports, and meetings from the WIV also suggest that the WIV experienced
persistent biosafety problems relevant to the containment of an aerosolized respiratory virus like SARSCoV-2:


In May 2019, the Director of the WIV BSL4 laboratory warned that in high-containment
laboratories in China maintenance costs were neglected and part-time researchers made it “difficult
to identify and mitigate potential safety hazards in facility and equipment operation earlyenough.” (emphasis added) 216



Leadership at the WIV emphasized during a June 2019 meeting with WIV officials that addressing
the “stranglehold problem” was critical to “pushing forward the construction and… developmentof science and technology for the nation.”217

In July 2019, the deputy director of the BSL4 laboratory issued a report on shortages of biosafety
equipment and its impact on meeting the research expectations of the government.218

24

In July 2019, China’s National People’s Congress began the process of drafting the law tostrengthen the management of laboratories involved in pathogen research and improve adherence
to national standards and requirements for biosafety.219

A November 12, 2019 report suggested a biosafety problem had occurred at the WIV sometime
before November 2019.220

On November 19, 2019, the WIV hosted a special training session by the senior Chinese Academyof Sciences biosafety/biosecurity official who relayed “important oral and written instructions”
from PRC leadership to the WIV regarding the “complex and grave situation facing [bio]security
work.”221 This one-day training session for senior leadership was followed on November 20-21,
2019 with two days of safety training for personnel from the WIV and other Wuhan area highcontainment laboratories.

d. Anomalies in Epidemiology of SARS-COV-2 Outbreak

SARS-CoV-2 spilled over into humans only in Wuhan.222 This is a break with the precedent of
SARS, MERS, and multiple outbreaks of avian influenza, all of which were much less transmissible
than SARS-CoV-2 and infected fewer animals.

The low genetic diversity of the earliest SARS-CoV-2 samples, coupled with one of the two earlylineages being more closely related to bat coronaviruses, suggests that COVID-19 pandemic ismost likely the result of one, or at most two, spillovers of SARS-CoV-2.223 SARS-CoV-2’s low
initial genetic diversity is also a break with the precedent of recent zoonotic spillovers of respiratory
viruses.



Critical corroborating evidence of a natural zoonotic spillover is missing. While the absence ofevidence is not itself evidence, the lack of corroborating evidence of a zoonotic spillover orspillovers, three years into the pandemic, is highly problematic. If the COVID-19 pandemic is theresult of the zoonotic spillover of SARS-CoV-2 in Wuhan from an intermediate host species, there
should be evidence of SARS-CoV-2 circulating in animals before it spilled over into humans.
Instead, there is no evidence that any animal was infected with SARS-CoV-2 prior to the firsthuman cases.224

25

Conclusion
As noted by the WHO Scientific Advisory Group for the Origins of Novel Pathogens, the COVID19 Lancet Commission, and the U.S. Office of the Director of National Intelligence 90-Day Assessment on
the COVID-19 Origins, more information is needed to arrive at a more precise, if not a definitive,
understanding of the origins of SARS-CoV-2 and how the COVID-19 pandemic began.225 Governments,
leaders, public health officials, and scientists involved in addressing the COVID-19 pandemic and working
to prevent future pandemics, must commit to greater transparency, engagement, and responsibility in theirefforts.
Based on the analysis of the publicly available information, it appears reasonable to conclude that
the COVID-19 pandemic was, more likely than not, the result of a research-related incident. New
information, made publicly available and independently verifiable, could change this assessment. However,
the hypothesis of a natural zoonotic origin no longer deserves the benefit of the doubt, or the presumptionof accuracy. The following are critical outstanding questions that would need to be addressed to be able tomore definitively conclude the origins of SARS-CoV-2:What is the intermediate host species for SARS-CoV-2? Where did it first infect humans?
Where is SARS-CoV-2’s viral reservoir?
How did SARS-CoV-2 acquire its unique genetic features, such as its furin cleavage site?

Advocates of a zoonotic origin theory must provide clear and convincing evidence that a natural
zoonotic spillover is the source of the pandemic, as was demonstrated for the 2002-2004 SARS outbreak.
In other words, there needs to be verifiable evidence that a natural zoonotic spillover actually occurred, notsimply that such a spillover could have occurred.

26

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