already received a great deal of positive feed-back and requests for 
participation from HIMA member scientists* 
I would now like to offer a few comments on the NIOSH/CDC proposal for 
medical surveillance of the Biotechnology Industry. HIMA believes 
that while the NIOSH/CDC proposal has thoughtfully considered the 
majority of the pertinent Issues, It does not come to the proper 
conclusion. The proposal Itself clearly documents several solid 
reasons why such a project should not be undertaken. To quote from the 
document, they are as follows: "The health hazards of exposure to 
altered micro-organisms appear minimal; medical surveillance of 
workers Is Inherently limited In Its ability to detect disease; 
groups under study will be relatively small, Individual 
exposures will vary; potentially there will be long latent 
periods . " 
In spite of these negative factors, NIOSH recommended surveillance on 
the basis of two weak arguments. These are that medical surveillance 
(1) affords a means for assessing the effectiveness of physical and 
biological containment and (2) It provides for early detection of 
unanticipated Illness. The first argument Is valid only If the 
process Involves organisms which produce some known disease, l.e., 
when there Is something to measure. Yet NIOSH has also said that "the 
health hazards of exposure to altered micro-organisms appear to be 
minimal. Thus, the first argument for surveillance has no rationale 
2 
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