the researcher, but does not eliminate the potential conflict of 
interest. The biohazard committee, interested in the institution's 
prestige emd funding may be less than objective when violations come 
to its attention. If a responsible local health official were a 
member of such committees, cin additional safeguard would be added. 
The biohazard committees should be required to conduct periodic 
inspections , hold regular meetings , cuid maintain records and reports 
of facility maintencuice emd inspection which should automatically be 
submitted to NIH. A minimum schedule for inspections, meetings and 
reports should be estciblished. In institutional settings, it may be 
the institution and not the researcher who is in charge of laboratory 
maintanance. The respective responsibilities of researcher amd 
committee should be spelled out as part of every grant application. 
Without specific requirements, a biohazard committee could exist for 
appearances only. 
The role of the NIH staff is enforcing compliance is critical, 
yet this subject is left vague by the Guidelines. Inspections of P3 as 
well as P4 facilities should be required by staff at frequent intervals. 
Periodic research emd maintencuice reports should be submitted to a 
central committee to inform the staff of containment success or la±>ora- 
toiry problems . Reports of laboratory equipment malfunctions or worker 
contamination would allow staff to evaluate the Guidelines for possible 
revisions in the future. 
The only true enforcement mechanism afforded by the cxirrent 
Guidelines is graint termination. If ein accident should occur because 
of unenforced or slack containment practices, grant termination would 
- 28 - 
Appendix K — 108 
