NIH grantees cannot be expected to police 
themselves effectively. They will always have a stong 
competitive interest in pushing research ahead and, when their 
desire to complete research conflicts with adherence to 
the Guidelines, safety procedures will be bent. The 
competitive pressures on NIH grantees will be particularly 
great if non-NIH researchers are not subject to any safety 
procedures . 
Under the Guidelines the demands on the time of NIH 
staff will be so great that they will not be able to monitor 
effectively the compliance of facilities with physical 
containment requirements or monitor the health of laboratory 
workers , which unfortunately is the only available means of check! 
for "leaks" of recombinant DNA molecules. Because of the number 
of complex factual determinations the staff is required to 
make, virtually all of their time is likely to be spent reviewing 
and deciding applications. The task of monitoring is made more 
difficult because the Guidelines do not limit the number of 
facilities where recombinant research can be conducted. 
NRDC recommends that the Guidelines be revised and 
promulgated by the Secretary of HEW as regulations binding on 
all parties conducting recombinant research. The revised 
Guidelines should contain enforcement provisions based on 
licensing of facilities to ensure compliance with physical 
26 
Appendix K — 152 
