surely be a case of 'too little, too late' Violations disclosed 
in the periodic reports made by the inspectors on equipment maintance 
cuid containment practice adherence would alert the central agency to 
recalcitrcuit grantees . 
The all-or-nothing approach of grant termination may maike any 
enforcement difficult. More limited penalty options for violations 
of grauits should be incorporated into the contracts. Such clauses 
could require increasing the level of contciinment required or use of 
additional safety equipment. Quarterly reports with grant reevaluation 
would also be a useful tool. 
NIH should consider establishing a federal program of cooperation 
with state health departments to utilize state inspection capabilities. 
Similar systems now operate in the areas of air and water pollution 
control . 
Finally, the Guidelines should require minimum training stauidards 
in biohazard control for all personnel working in recombincuit research 
laboratories . Grantees should submit both employee progreun training 
amd emergency procedure plans . 
-29- 
Appendix K — 109 
