This article reports on published government documents, on a public Bill before Parliament, and on evidence given in open court. Quotations are from the published report of the 2003 Review Panel, from the Bill itself, from the Notes of Evidence, or from exhibits in evidence. The criminal proceedings described are ongoing and no finding has been made. I make no allegation of wrongdoing against any person.
Parliament is about to hand control of Singapore’s most dangerous pathogens to a single office — the Chief Executive of the Health Sciences Authority. In 2003, after SARS escaped from a Singapore laboratory, a review panel convened at our own Ministry of Health’s request set out precisely what safeguards this work requires. This is what they said, what this Bill does about it, and what I found when I tested those safeguards myself — three case studies, in 2003, 2022 and 2024.
1 · The Bill
The upcoming Amendment to the HSA Bill, Tuesday 8 September 2026
On Tuesday 8 September 2026, Parliament debates the Health Sciences Authority (Amendment) and Other Matters Bill.
Among other things, the Bill takes the Biological Agents and Toxins Act — the law that controls who in Singapore may possess, grow, import and transfer anthrax, plague, botulinum toxin, Ebola, Marburg, Nipah, MERS, SARS and smallpox, and which laboratories may hold them — and moves its administration from the Director-General of Health into the office of HSA’s Chief Executive.
Before that vote, I want to put one document in front of you. Not mine. The Government’s.
In September 2003, three months after Singapore was declared free of SARS, the virus came back — out of a laboratory here. A 27-year-old man in his third year of a doctorate in microbiology at the National University of Singapore was infected. He believed he was working on West Nile virus. He was not told, and did not know, that the samples he handled had been cross-contaminated with live SARS coronavirus.
To its considerable credit, the Government did not handle this quietly. The Ministry of Health convened an eleven-member review panel, including international biosafety experts and the World Health Organization, asked it to examine what had happened, and published its findings in full. They sit in the National Archives today. I have read them beside this Bill, and I think every Member of Parliament should do the same before Tuesday.
Because the panel did not just explain the accident. It set out what this work requires in order to be safe. And the standards it wrote are the measure against which I would ask you to judge the Bill — and, later in this article, the conduct I have witnessed at first hand.
2 · Case study one — the warning, 2003
What the panel said we needed
Read these in the panel’s own words.
On the cause:
From the results of the epidemiologic investigation surrounding the recent case of SARS, it appears that inappropriate laboratory standards and a cross contamination of West Nile virus samples with SARS coronavirus in the laboratory led to the infection of the doctoral student.
On records. The panel found the documentation so poor that basic questions could not be answered:
Although it refers to a daily record, there is no daily record of BSL-3 laboratory such as date, user name, time-in and out, remarks including negative pressure level and experiment…
And, on knowing where the pathogens actually were:
There is no central database for virus stock and location in the freezers.
On the absence of law. This is the finding that changed everything:
Singapore has no accepted or legislated standards for biological safety (biosafety) … Consequently, there is no organisation or institution for laboratory or investigator accreditations.
That finding is why the Biological Agents and Toxins Act exists. It was enacted in 2005, in direct response. Which means the statute this Bill now rearranges is itself the product of the last time we lost control of a dangerous pathogen on this island.
- 7.1A national legislative basis for biosafety standards, with mandatory codes reviewed by expert panels at least every five years.
- 7.2A structure for laboratory certification covering both physical integrity and operating procedures, renewed annually, audited by “experienced and accredited external auditors”.
- 7.3A system to track dangerous agents — not only in and out of Singapore, but moving between laboratories within it.
In plain language: a documented chain of custody, so that at any moment someone can say where a dangerous organism is and who has handled it.
And then the panel wrote this, which I would ask you to read twice:
It is also important to encourage an atmosphere of trust and confidence that the team members are working safely and feel that they can openly communicate any of their concerns without discrimination. Staff need to be willing to immediately report any biological safety incidents and feel that they will be treated openly and without the threat of punishment. Otherwise, incidents may go unreported and then there may a very serious situation to resolve.
That is Singapore’s own review panel, commissioned by the Ministry of Health, saying in 2003 that a system which punishes people for raising concerns will not hear about its problems until they are past solving.
So the panel gave us four tests.
- 1Are the records complete?
- 2Is there a documented chain of custody?
- 3Is there independent audit?
- 4Can people raise concerns without fear?
Hold those four. Everything that follows is measured against them.
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Support This Work ↓3 · Case study two — the standards, tested
10.5 hours, off the record, on the night of 20 January 2022
Here I have to be careful, and I want to be plain with you about why.
I am an accused person. My criminal trial is ongoing and it will be decided by a judge on the evidence, not by anything published here — and I would not want it otherwise. Nothing in this section asks you to decide my guilt, or anyone else’s. The Ministry of Health is not on trial; neither is HSA. I am not writing about my charges.
What I am writing about is process — and I am doing it because I have had an unusual vantage point. For nearly two years I have stood in a courtroom and questioned, under oath, the officials who conducted an investigation. Very few citizens ever get to test, in public, whether the standards these institutions profess are the standards they keep. I did. This is what I found, measured against the panel’s four tests.
Every quotation below is a prosecution witness’s own sworn answer under cross-examination, or a document in evidence.
The night. On 20 January 2022, Dr Jipson Quah attended at an MOH office at Harbourfront Centre — Discussion Room 8, an office meeting room in a commercial building — to assist with an inquiry into antigen rapid tests at his clinics. At 3.30pm, MOH investigator Mr Mak Jia Yuan began recording a statement, exhibit P44. The warning read to Dr Quah was for a suspected breach of the ART provider regulations under the Infectious Diseases Act. Nineteen questions followed, every one about test kits.
Then the recording officer’s own note:
Statement recording paused at 1621 hrs for a break … At 1845 hrs, dinner was served … Statement recording resumed at 0255 hrs on 21 January 2022.
Ten and a half hours. The note records biscuits at 4.21pm, dinner at 6.45pm, four phone calls and one WhatsApp message. It does not record what else happened. Dr Quah remained there until about six in the morning, when he was taken to Central Police Division and a further statement was recorded from 6.55am, finishing around half past ten — by which time he had been awake roughly twenty-six hours.
1Test OneWere the records complete?
Start with the thing I most want Parliament to notice: the pause was not the investigator’s decision.
Mr Mak told the court — in examination-in-chief, questioned by the Prosecution, not by me — that during the break he updated the case officer in charge and his OC on the progress of the statement recording. And then:
I was then told to wait before resuming statement recording — told to wait for further instructions before resuming statement recording. I don’t remember being told the reason why I had to wait for further instructions.
He assumed it was because there was a need to verify information. And then:
Subsequently, a few hours later, I was told that … DDMS Raymond Chua was on his way to Harbourfront Centre and he wanted to speak to Dr Quah.
So the ten and a half hours were ordered from above. The officer conducting the interview was instructed to stop. He was not told why. He waited. His superior arrived and spoke to the man for hours, and nothing of it was written down. And when recording resumed at 2.55am, the questions were about a different offence.
Why was the recording paused? I have asked for that answer through the court’s disclosure process. I may or may not receive it, and that is a matter for the criminal court, not for this article.
But whether an instruction of that kind should exist only in someone’s memory is not a matter for the criminal court at all. It is a question about how our institutions are built — and it is precisely the question before Parliament on Tuesday.
And there is one question that was never put to Mr Mak by anyone — including me. Could he have refused? I do not say he should have. I do not know what he could have refused. That is the problem. An investigator told by management to pause a recording, and given no reason, has no rule to point to, no form to complete, and no one to report it to. Whether he had any standing to object was never asked — and I suspect the honest answer is that nobody knows, because nothing in the system defines it.
The 2003 panel’s fourth principle was that people must be able to raise concerns “without the threat of punishment.” We naturally read that as protection for the citizen, or for the laboratory technician who spots a breach. Read it again with this night in mind. It also protects the officer in the room — the one who is told to stop, and to wait, and is not told why.
And the basis for that is not sentiment. It is the rule of law.
The rule of law means that public power is exercised according to law, not according to rank. An officer’s duty runs to the statute he acts under — not to the person standing above him in the reporting line. It follows that where an instruction would take an investigation outside its lawful bounds, carrying it out does not cure the defect. It spreads it.
Which is why the ability to question a superior officer is not insubordination. It is the mechanism by which the law actually binds an institution. Remove it, and the safeguards Parliament writes into a statute become optional in practice — observed when convenient, set aside when someone senior enough says so, and unprovable either way because nothing was recorded. A system with no route for that question has quietly made rank, rather than law, the source of authority.
That is the whole reason records and independent review matter. They are what make it possible for a junior officer to say “show me the basis” — and for the answer to exist.
What in this Bill gives that officer anything to stand on?
During that gap, the Deputy Director of Medical Services — DDMS, as Mr Mak called him — Dr Raymond Chua — came to the building and spoke with Dr Quah for hours; exactly how many hours, no one knows. (Dr Chua became Deputy Director-General of Health later in 2022. Today he is Chief Executive of the Health Sciences Authority — the office this Bill is about to enlarge.)
There is no note of that conversation. None. I asked Mr Mak what was said:
I wasn’t paying attention, I did not take any notes and I can’t remember now.
Was DDMS a trained investigator? “As far as I’m aware, no.” Was it usual? “Unusual because I’ve not seen it before.” Did it matter to the statement he then recorded? “Immaterial.” Asked how he classified the episode at all, he said: “to be consistent, it is a conversation.” On that classification — his own — every safeguard that attaches to a statement fell away.
Recording resumed at 2.55am. Question 20, the first after the gap, is the first mention anywhere in that statement of saline injections given in place of vaccines.
His memory of the night began firm and did not stay that way. He was “very sure” DDMS had not been present when two individuals were brought in and shown to Dr Quah for identification at 12.43am and 2.30am. But he could not say when the conversation had happened. Asked to set aside what the usual procedure would have been and think about what actually occurred that night — a night he had agreed was not usual — he said: “I cannot see the scene of the identifying process in my mind anymore.” And finally: “I cannot remember, but agree it is possible.”
Two more answers. Would DDMS have a strong presence in the room? “Your Honour, he was in the room. He had a presence.” And: “He is your boss. So, if your boss is in the room, you will be more attentive. Agree?” — “Yes, agree, Your Honour.”
In fairness to Mr Mak, he agreed a great deal — and what he agreed matters more than what he disputed.
He agreed that MOH has no power to investigate cheating offences. He agreed that MOH has no authority to detain people overnight in facilities not meant for detention. He agreed that an investigator must be trained, must exercise independence of thought, must not pre-judge an outcome, and must not be influenced in his findings. He agreed it was unusual — that he had not seen it before — for DDMS to step in and question his interviewee. He agreed his superior “was in the room. He had a presence,” and that with his boss in the room he would be more attentive. He agreed that, procedurally, closing the investigation and administering a fresh warning “might have been the right thing to do.”
What he disputed were my conclusions, not the standards. His position is that the conversation was immaterial and did not influence him; that the scope had already widened earlier that afternoon when WhatsApp messages were extracted from Dr Quah’s phone; that colleagues were tasked with retrieving records; and that MOH’s concern was a genuine public-health one throughout. He disagreed that the ART inquiry was a pretext, and that MOH was, in this instance, investigating a cheating offence at all. That is his evidence, it is on the record, and it is for the judge to weigh — not for me.
But the panel’s test is not about who is right. It is about whether a record exists. It does not.
2Test TwoWas there a documented chain of custody?
The panel asked, in 2003, for a documented trail for dangerous organisms moving between laboratories. A chain of custody exists so that anyone can later establish who held a thing, when, and on whose authority.
In my own case, phones were seized and moved between agencies. No document has been produced to us showing that chain of custody — how a device passed from the Ministry of Health to the police, or who signed for it. That question is currently before the court and I will say no more about it here.
I raise it only for the comparison, and the comparison is the whole point: if a documented trail cannot be produced for a mobile telephone, what confidence should Parliament have in the trail for a vial of anthrax?
Four years of hearings went into the pages you are reading. There is no advertiser and no proprietor behind them — only readers.
Support This Work ↓3Test ThreeWas there independent scrutiny — and were the rules followed?
The panel wanted external, accredited auditors. Here is what internal process looked like.
I asked Mr Mak whether the Ministry of Health can investigate cheating:
MOH does not have powers to investigate cheating offences.
That investigation ended in charges of cheating and criminal conspiracy — mine is brought under section 120B read with section 424A(3) of the Penal Code, which carries up to twenty years’ imprisonment. I put to him that MOH “has no authority to detain people from overnight … in facilities that are not meant for detention.” His answer was one word: “Agree, Your Honour.” A Senior Assistant Director, Mr Lee Woon Lin, said the same of another accused: “We don’t have legal powers to the best of my recollection.”
The interview room bore that out. Mr Mak agreed “the facility may not be built for people to rest, because it is after all an office building”, and that “there was no bed, no pillows, no blankets in the interview room.”
And the evidence that would have tested the allegation was never gathered. Did he retrieve any medical or patient records to verify the ART allegation? “Your Honour, I did not.” Were any syringes or vials seized or tested to establish what had actually been injected? “No, I did not, Your Honour.” What was put to Dr Quah was private WhatsApp messages. No vial was tested. No clinic record was pulled. But the private messages were read.
Nor could anyone say how the investigation began. “I did not receive the First Information and I do not know what is entailed in the First Information.” The police report that opens the file was lodged by a duty senior investigation officer on a superior’s telephone instruction, on behalf of an MOH officer whose name he could not remember, and marked sensitive. The police officer was also asked to put his own name as the informant instead of the MOH officer — an officer who, at the time of the report, had had no interactions with the accused persons at all.
That instruction came from his supervisor, Mr Ho Cher Hin, by telephone, before 3.54am. Asked what he had been told, his evidence was:
I cannot remember clearly, but what I can recall is just inform me that someone is coming over and I will need to facilitate to lodge a report and put under sensitive.
He was asked whether he was told why he should name himself as the informant. “No.” He was asked whether he was told why the report should be marked sensitive. “No.” He could not remember the name of the MOH officer who supplied the facts he typed.
Whether Mr Ho decided that himself, or was himself acting on instruction, is a question I am still asking. Nothing produced to us answers it.
On the Ministry’s side, the picture is no clearer. Mr Lee Woon Lin, the Senior Assistant Director quoted earlier, agreed he had a supervisory role that night. He believed the report had been made by his own officer, Mr Brian Tan. Shown the name that actually appears on it, he said: “This name doesn’t look familiar to me.” Asked why the report was made by Lee Shi Jie and not Brian Tan, his answer was: “I cannot answer this question.”
And that is the point. The genesis of this investigation — where it came from, how it began, what was said and by whom — is off the record. Even the first information report, the one document whose entire purpose is to record how a case begins, carries an informant’s name that is not the source of the information. The panel’s first test was whether the records are complete. On this file the record does not merely fall silent for ten and a half hours on the night of 20 January. It is silent at the very beginning.
And neither Dr Quah nor Mr Thomas Chua was ever charged with any ART offence — the matter the whole inquiry was, on paper, about.
4Test FourWas there informed consent?
This is the one that troubles me most, because it is the medical principle turned inside out.
Informed consent is the foundation of medicine. A person is told what a product is, what it may do to them, and what the alternatives are — and only then is their “yes” worth anything. HSA exists to make that possible. The Human Biomedical Research Act, which this Bill also hands to HSA’s Chief Executive, is built on that same principle from its first page.
The warning read to Dr Quah at 3.30pm was about test kits. The further statement at 4.30am — the one containing the answers about saline injections, and about me — carries the same warning. The same regulation. The same Act. At no point that night was he warned he was being questioned about fake vaccinations.
I asked why not. “It did not cross my mind at the time, Your Honour.” Should he have closed the ART investigation and opened a new one with a fresh warning? “I can agree that procedural-wise, that might have been the right thing to do.” And of the very questions that produced the answers now relied on:
I did not give him a separate warning, and I did not tell him that he is under the law to furnish information within his knowledge. But yet he did so.
To that I asked him: “Oh, so it’s his fault again?”
No, Your Honour. I’m not saying that it’s Dr Quah’s fault. But I — my view, I think it is forthcoming.
A warning is not a formality that a forthcoming answer can replace. It is the thing that tells a man what he is answering to.
Then this. I asked Mr Mak about his own training — whether training is required to be an investigator (“Agree, Your Honour”), whether it covers ethical conduct, and asked him to name an example. He chose, unprompted, the warning: before recording a statement, the recorder “would be required to administer a warning to the interviewee.” He named it himself as the ethic. He did not do it.
I asked whether an investigator must exercise independence of thought. “Agree, Your Honour.” Whether he should pre-judge an outcome. “No, Your Honour.” Whether the work is the objective collection of facts. “Agree, Your Honour.” Whether, beyond information passed to him by colleagues, he is not to be influenced in his findings. “Agree, Your Honour.”
Every standard, correctly stated. And on the night in question, on the evidence, not one of them recorded as met.
Dr Quah answered questions for a twenty-year offence while believing he was helping a regulator with a question about test kits. That is not informed consent to anything. The agency that enforces informed consent in medicine did not practise it in its own interview room.
So I would put two questions to Parliament, and neither is rhetorical.
First: what prevents this from being repeated? If an institution can require a person to answer under one law while investigating him under another, and no rule compels it to say so, then the protection exists only where the institution chooses to apply it. A consent that an agency may switch off at will is not consent. It is permission it has granted itself. The Bill moves the Human Biomedical Research Act — our law of consent — into the office of the Chief Executive of HSA, and adds nothing that would require whoever holds that office to say what is really being asked.
Second: what protects the person who speaks up? I raised concerns about how the COVID-19 vaccines were being rolled out. What came back was not an answer to those concerns. The 2003 panel put this in terms, and it is worth repeating here: people must be able to report what troubles them “without the threat of punishment”, or incidents go unreported until there is “a very serious situation to resolve.” That was written about laboratory staff and biological agents. I would ask Parliament whether the principle stops there — and what, in sixty-six pages, protects the technician, the doctor, the ordinary citizen who raises a concern about a facility, an approval or a decision, and the officer inside the institution who is told to stop and not told why.
Nothing in this Bill answers either question. An institution which proceeds this way on a weeknight in an office block is not obviously the institution to be handed, without new safeguards, the law of consent and the keys to the pathogen registry.
And the obvious reply — that all of this was MOH, while the Bill gives the powers to HSA — does not hold as neatly as it looks. The officer who came to Harbourfront Centre that night was the Deputy Director of Medical Services. He is today the Chief Executive of the Health Sciences Authority; when that appointment was announced in December 2024, HSA said he would continue concurrently as Deputy Director-General of Health (Health Regulation).
I am not alleging wrongdoing by him or by anyone. The point is structural, and it would be the same point whoever held the post. On the organisation chart the two bodies are separate. In practice the offices can meet in one person — and a safeguard that relies on the distance between two institutions provides nothing where that distance does not exist.
Everything here is free to read, and always will be. The transcripts, the filing fees and the costs orders were not free to obtain.
Support This Work ↓4 · The Bill against the standard
What the Bill actually does — measured against those four tests
You have just seen what it looks like when those four things are missing. Here is what the Bill does about them — not vaguely, but specifically. The clauses are short and you can check every one.
Clause 18 inserts a new definition into the Biological Agents and Toxins Act: “‘Chief Executive’ means the Chief Executive of the Authority appointed under section 15 of the Health Sciences Authority Act 2001.” That office does not currently appear anywhere in that Act. Clause 18 creates the chair.
Clause 22(1) fills it. In thirty-five separate provisions, the words “Director-General” are replaced by “Chief Executive”: approvals to possess, large-scale production, import and transhipment permits, transfers between facilities, facility certification, directions, enforcement. The Bill’s own Explanatory Statement says Part 2 amends the Act “primarily to replace references to the DGH with the Chief Executive of the HSA.”
To be fair to the drafters, and I would rather put their case than have it put to me: for the gravest powers, clause 22(2) requires the Chief Executive to act “after consulting the Director-General” — the DGH does not vanish. HSA remains a statutory board. New section 5A(1)(a) provides that its Chairperson must be a member other than the Chief Executive, so he cannot chair his own board. Those are real safeguards and they should be acknowledged.
Now put the Bill against the panel’s four tests.
One — Are complete records required?
No. Clause 22(2) requires the Chief Executive to consult the Director-General before the gravest decisions, but the Bill nowhere requires that consultation to be recorded. It does not say what happens if the Director-General disagrees. It gives nobody outside any means of knowing it occurred at all.
Nor does clause 19 require reasons. The Chief Executive may permit a First Schedule agent — anthrax, plague, botulinum toxin — into an uncertified facility where he “is satisfied” it will be handled safely. Satisfied on what material, recorded where, reviewable by whom? The Bill does not say.
Clause 21 protects officers personally where they act “in good faith and with reasonable care.” That is a real standard and a fair one. But to test whether an officer met it, you would need to know what he was told, by whom, and on what basis he acted — and the Bill requires none of that to be written down. A condition nobody can test is not much of a condition. (Clause 20 sends fees collected under the Act to the Authority.)
Two — Is there a documented chain of custody?
Partly, and untested. The Act carries transfer provisions, and the Bill moves them to the Chief Executive. But whether the tracking system the panel asked for in 2003 was ever built, what it holds, and who audits it, I have not been able to establish from any public source. The Bill does not create one, and does not require anyone to report on the one that was recommended.
Three — Is there independent audit or review?
None is created. The panel asked for certification renewed annually and audited by “experienced and accredited external auditors.” The Bill contains no external audit requirement.
Clause 21 protects the officer; nothing in the Bill provides for review of the Authority’s decision. The Chairperson and Deputy Chairperson are Ministerial appointments which the Minister may also revoke. And in sixty-six pages, the word “appeal” does not appear once.
Four — Can people raise concerns without fear?
The Bill says nothing at all.
And it goes further in the opposite direction. Clause 24 allows the Chief Executive to appoint “any suitably qualified individual” — expressly including persons who are neither public officers nor officers of a public authority — as auxiliary authorised officers, to enter premises and require the production of documents. The Bill does not define “suitably qualified”, does not say who assesses it, and requires no published criteria, no register, no training standard, and no route by which a clinic, a laboratory or a doctor may complain about one. Obstructing such an officer is punishable by up to $20,000 or two years’ imprisonment. In fairness, the Bill deems them public servants for the purposes of the Penal Code, so they may be prosecuted for corruption — but that is a sanction after the event, not a qualification before it.
So the person on the receiving end has a defined penalty for obstruction and no defined way to object.
- 1Are the records complete?No
- 2Is there a documented chain of custody?Partly
- 3Is there independent audit?No
- 4Can people raise concerns without fear?No
On the face of this Bill, that is how it scores.
And one thing the panel could take for granted, which we no longer can
In 2003 these functions sat in different places. The Director-General of Health, a medical office inside a ministry, decided who could possess dangerous pathogens. HSA, a statutory board, regulated health products. MOH’s Health Regulation Group licensed premises. Three offices, three professional cultures, three sets of eyes — and friction between them. Nobody designed that friction as a safeguard, but it worked as one: a lapse of judgment or culture in one office did not automatically become the position of all three.
The Bill, together with the transfer MOH announced to licensees in August, collapses that. The Health Regulation Group moves into HSA by the end of 2026, and the secretariat of the professional boards by the end of 2027, while the pathogen and human-research powers move to the Chief Executive. What the Ministry’s letter calls “an integrated regulatory hub” is, viewed as safety design, the removal of institutional diversity: one office approving who may hold anthrax, certifying the facility, licensing the premises, inspecting it, and housing the secretariat of the boards that discipline the professionals inside it.
The 2003 panel assumed the opposite. It asked for certification audited by “experienced and accredited external auditors” — external to the body being examined. The more functions sit inside one authority, the fewer places “external” can be found.
And there is a feature of a country this small which is nobody’s fault, and which the Bill ignores. The person who will hold these powers, Adj Prof (Dr) Raymond Chua, also holds an adjunct professorship at the Centre of Regulatory Excellence at Duke-NUS and sits on that Centre’s advisory board, and an adjunct professorship at the NUS Saw Swee Hock School of Public Health. These are academic and advisory appointments in regulatory science — not executive roles — and they are entirely public: Duke-NUS lists them, and MOH’s own announcement of his appointment referred to one of them. In a system our size, senior regulators will inevitably hold appointments at institutions they regulate, and it is often a good thing that they do. Expertise is not abundant, and it should circulate.
There is a further point, and it comes from MOH’s own announcement of his appointment. The Ministry recorded that he “has led multiple transformative regulatory initiatives, including the enactment and implementation of the Human Biomedical Research Act and Healthcare Services Act, which modernised the healthcare regulatory framework.”
Those are two of the very Acts this Bill moves into his office.
I want to be careful, because this is not a criticism — it is the reason he was appointed, and it is a real advantage. Continuity of expertise matters, and a regulator who understands a framework from the inside will usually administer it better than one who does not. But notice what has now been assembled in a single place: the official who led the enactment of the Human Biomedical Research Act, who led its implementation, will hold the powers under it — and under the Biological Agents and Toxins Act — with no requirement to record his reasons and no independent body to review his decisions.
Concentration of expertise and concentration of authority are not the same thing. This Bill treats them as though they were.
Which is exactly why the safeguard cannot be the separation of people. It has to be the separation of process.
Duke-NUS and NUS operate laboratories regulated under the Biological Agents and Toxins Act. After Tuesday, the Chief Executive of HSA decides who may possess the agents held in them, which of their facilities are certified, and who inspects them. The question is therefore not about anyone’s integrity. It is this:
What in this Bill requires an interest to be declared, a decision to be recorded, or a recusal to take place?
Nothing. There is no declaration requirement, no recusal provision, no register, and no independent review of the decision afterwards. In a small country, where overlap is unavoidable, those are the only things that can do the work.
5 · Case study three — the remedy, tested
Then who checks the regulator?
The natural answer is that surely someone does. I went looking, and I had to pay a heavy price to find out — $12,000, to be exact.
The courts. In June 2024 my husband and I asked the High Court to compel HSA to act on the advertising rules — celebrities being used to promote vaccination. We lost. On 19 September 2024 the application was struck out. What matters is why: State Counsel submitted, and the court accepted, that HSA “may” order a corrective measure but is under no duty to enforce and no duty to prosecute, having prosecutorial discretion; and that we had no standing to ask, because a citizen with a general concern that the law be observed is, in law, a busybody. HSA told the court it had investigated the matter — but what it found, and why it went no further, was never published, and the court confirmed nobody is entitled to make it say. Costs of $12,000 were ordered against us. That is what it cost to establish that the courtroom is not where this question can be answered.
An internal watchdog. There is none. A complaint about how an investigation was conducted goes back into the same chain of institutions that conducted it.
The ethics body. The Bioethics Advisory Committee, established in the early 2000s to advise on the ethics of human biomedical research, describes itself as “a policy advisory body, not an executive body.” It has no regulatory or supervisory power. It does not adjudicate research proposals. It does not oversee institutional review boards. It does not hear appeals. It is not a watchdog over government or researchers. That is not a criticism — it is doing the job it was designed for. But it means that if you assumed an independent ethical check existed, on the evidence, it does not.
Three doors. All three shut. And this Bill opens none of them.
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6 · The ask
What I am asking Parliament
Not to reject the Bill. To pause on it, until these have public answers.
Question 1 — the Bioethics Advisory Committee
The Bill moves the Human Biomedical Research Act — our law of consent for research on human beings — into the office of HSA’s Chief Executive. Was the BAC consulted on that transfer? Will its advice be published? And once the Act sits inside HSA, what does the BAC actually oversee — anything?
Why it matters. This is the question I would most like answered before Tuesday. A law of consent handed to an institution with no independent ethics check above it is a contradiction Parliament should not pass without noticing.
Question 2 — records
The Bill requires consultation before the gravest decisions but does not require that consultation to be written down. Why not?
Why it matters. The 2003 panel found that when records are poor, nobody can reconstruct what happened. A decision nobody records is a decision nobody can check — and, as I have learned, that cuts both ways: it leaves the official as unable to prove what he did as the citizen is to question it.
Question 3 — interests and recusal
What declaration-of-interest and recusal requirements apply to the Chief Executive when exercising powers under the Biological Agents and Toxins Act in relation to an institution with which he holds an appointment? Where is that declaration recorded, and who may see it?
Why it matters. The Chief Executive will decide who may possess First Schedule biological agents and which laboratories are certified to hold them. Senior regulators here commonly hold academic appointments at the institutions they regulate — unavoidable in a country this size, and often useful. Which is exactly why the process, not the person, must carry the safeguard.
Question 4 — the chain of custody
Recommendation 7.3, twenty-three years ago, asked for a tracking system for dangerous agents moving between laboratories. Was it built? What does it hold? Who audits it?
Why it matters. Without it, no one can say where a dangerous organism is, or who has handled it.
Question 5 — independent audit
Recommendation 7.2 asked for certification renewed annually and audited by experienced and accredited external auditors. Where are they in this Bill?
Why it matters. The more functions sit inside one authority, the fewer places “external” can be found.
Question 6 — speaking up, for everyone
What in this Bill protects the laboratory technician who spots a breach, the doctor who questions an approval, the citizen who raises a concern — and the officer inside the institution who is told to do something he believes is wrong?
Why it matters. The panel warned that incidents go unreported where people fear punishment. A protection that covers only outsiders protects almost nobody, because the people who see a problem first are nearly always inside.
Conclusion
There is a reason I keep returning to records rather than to people, and it is not an accusation against anybody.
Personalities — good and bad, ours and other countries’ — are the wrong foundation for a safety system. Dr Chua will not hold his office forever. Neither will the present Minister. The Bill will outlast them both.
The 2003 panel understood this. It did not ask for better people. It asked for complete records, a documented chain of custody, independent accredited audit, and a culture in which concerns can be raised without fear of punishment. Not one of those four depends on anyone’s character. That is exactly why they work — and why, twenty-three years later, they remain the best protection we have against the next pathogen leaving a laboratory, and against the next person being made to answer for something nobody told them they were being asked.
In 2003 a dangerous pathogen escaped a laboratory in Singapore. The Government did the right thing: it invited outside experts, it published their findings, and it legislated. The panel told us what safety in this field depends on — complete records, a documented chain of custody, independent audit, and people who can speak without fear.
Twenty-three years later, Parliament proposes to take the very Act that grew out of that episode and concentrate it in one office, with none of those four things written into the Bill.
I am not asking you to take my word for what these institutions are like. I am asking you to notice that when I tested them — in the one forum where an ordinary person can compel an answer, under oath, in open court — the records were not there, the trail could not be produced, the boundaries of authority were conceded, and the person in the room was never told what he was really being asked.
I went through it. Take it as the panel meant its own warning to be taken.
The documents are all online and free to read at healingthedivide.cc/disclosure. Chapter 1 tells the 2003 laboratory story in full, with the panel’s report as an exhibit. Chapter 7 sets out this Bill clause by clause. This article is the door; the evidence is behind it.
What you can do — five minutes
- Read the documents. Everything is online and free at healingthedivide.cc/disclosure. Chapter 1 tells the 2003 laboratory story in full, with the panel’s report as an exhibit. Chapter 7 sets out this Bill clause by clause.
- Write to your MP before Tuesday. The questions, and a letter you can send in five minutes, are at healingthedivide.cc/writetomp.
- Share this with a doctor, a nurse, a researcher, a lawyer. Almost nobody has heard of this Bill. That is precisely how it passes.
Truth · Conscience · Courage · For a better world
Healing the Divide — Iris Koh
Different ways to support this work
Everything here is free to read and always will be. The documents, the transcripts, the filing fees and the costs orders are not free to obtain. If this was worth your time, here is what helps.
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AI for legal matters and rights — built out of everything this case forced me to learn.
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I have never taken an advertiser, a proprietor or an institution. That is why this article can say what it says. Thank you to everyone who has kept it that way.
This article reports on published government documents, on a public Bill before Parliament, and on evidence given in open court, and expresses honestly held opinions on matters of public interest. It does not allege wrongdoing by any person or institution. The criminal proceedings described are ongoing and no finding has been made.
Sources. Review Panel on the New SARS Case and Biosafety, Ministry of Health / World Health Organization, September 2003 (National Archives of Singapore). Health Sciences Authority (Amendment) and Other Matters Bill No. 17/2026, clauses 18–24 and Explanatory Statement. Biological Agents and Toxins Act 2005. Notes of Evidence and exhibits in the ongoing criminal proceedings. HC/OA 554/2024. Bioethics Advisory Committee, bioethics-singapore.gov.sg.


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