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E. Compliance with the Guidelines 
A number of commentators recommended that there be a more 
complete discussion on NIH implementation of the Guidelines [20, 26, 29]. 
Appendix D to Appendix C of the EIS now contains memorandums from 
Dr. William Gartland, Director of the Office of Recombinant DNA 
Activities (ORDA), to all NIH grantee institutions and contractors which 
provide the structure for the implementation. The text of the EIS has 
been expanded to explain more fully compliance procedures and 
responsibility. 
Some commentators suggested that membership of Institutional 
Biohazards Committees should include specialists in population dynamics, 
ecology, and other disciplines [10, 20, 29]. The Guidelines recommend 
that committees have representatives with the competence to determine 
the acceptability of committee findings in terms of applicable laws, 
regulations, standards of practices, community attitudes, and health 
and environmental considerations. It is also recommended that repre- 
sentatives from disciplines relevant to recombinant DNA technology, 
biological safety, and engineering serve on the committees. Inclusion 
of specialists in ecology and population dynamics would be within the 
intent of the Guidelines for committee service. 
Some commentators were concerned that the Draft EIS did not 
emphasize relevant safety training for laboratory personnel [3,20]. 
The Guidelines, however, specifically require the principal investigator 
(with the overview of the Institutional Biohazards Committee) to ensure 
appropriate safety training of all personnel prior to the conduct of 
the experiment. Further, the Biohazards Committee must review and 
certify that the investigator does fulfill this responsibility, both at 
the time of initial application for research support and annually 
thereafter. 
The commentators generally noted the limited scope of the NIH 
Guidelines as not reaching research in the rest of the public sector 
or in the private sector [14, 1 7, 20, 26, 2 9]. As described below, 
however, (see Section VI-E) the Federal Interagency Committee on 
Recombinant DNA Research recommended that legislation be developed 
to regulate all recombinant DNA activities, and an Administration 
bill based on those recommendations was submitted to the Congress. 
Legislation is pending. 
Some commentators observed that the NIH sanction of terminating 
funds for violation of the Guidelines may not be the best approach 
[14, 20, 29], More limited actions might be taken; for example, higher 
containment levels or other safety steps might be required. The NIH 
will consider these suggestions in developing policy. The pending 
legislation imposes more stringent measures than those available to 
NIH alone. 
