T^y reduction in risks by physical containment is 
only possible if the containment equipment is 1) properly 
designed, 2) properly installed, 3) certified to be operating 
correctly, 4) used in an efficient and safe manner, and 5) 
inspected regularly. The Guidelines do not address this or 
contain provisions to ensure that these practices will be 
followed. 
The discussion of physical containment should clearly 
explain that such measures can only reduce risks to a limited 
extent, and accidents resulting from error can never be 
precluded. 
Other questioncdsle aspects of the Guidelines which 
should have been addressed in the DEIS include the following: 
1. A P 3 Level Iciboratory makes the safety measure 
of directional air flow and exhaust optional as long as a 
Biological Safety Cabinet with gloves and glove ports is used. 
Puncture rates of gloves can be quite high with subsequent 
escape of organisms. The degree of safety in using cabinets 
with gloves without directional air flow and negative air 
pressure should be discussed. 
2. The physical containment levels do not reauire the 
decontamination of waste water. After a recombinant experiment, 
a researcher washing his hands could wash away a recombinant 
organism which would then escape to a sewer system and proliferate. 
-16- 
Appendix K — 96 
