"No person other than a licensed practitioner 
of medicine, dentistry, or veterinary medicine or 
a person under the direct supervision of a 
licensed practitioner of medicine, dentistry, 
or veterinary medicine shall posess or cultivate 
live pathogenic microorgcinisms or viruses other 
them vaccine virus" 
without a registration number from the Department of Health or 
the New York City Health Services Administrator, Article 32 also 
prohibits the treinsfer of live pathogens and require Icibeling of 
containers. All NIH grantees in New York must comply with 
this article. 
The Guidelines should simil rly require mimimum 
qualifications for principal researchers which must be set forward 
in euiy graint application. These qualifications should include 
studies in toxicology and epidemiology, cind a detailed program 
for Iciboratory maintenance euid inspection. 
Under the existing Guidelines, the regulations for 
medical surveillance emd reporting should be strenghened. The 
Guidelines now require grantees to report accidents and infections . 
Realistically however, a report would only be made for severe 
infections Since most laboratory-acquired infections are not 
easily traced to their apparent source and since other illnesses 
euid minor complaints caused by breathing accidently produced 
aerosols are probably not considered to have such origin, they may 
never be reported. Small infections would go unreported and 
changes which are not immediately manifested would go unnoticed. 
Some infectious agents picked up in the laboratory might lie 
-26- 
Appendix K — 106 
