simultaneous notification to the IBC and not prior approval of 
the IBC. This approach seems particularly appropriate because 
classification as exempt means that the issue of safety has 
already been addressed. Moreover, large-scale experiments will 
be performed in a facility which has previously been approved by 
the relevant IBC. Within the IBA there is significant sentiment 
for requiring only simultaneous IBC notice -{as opposed to prior 
approval) for PI experiments as well as for exempt experiments. 
For your information many of our members supplement 
their IBC review with frequent monitoring through various kinds 
of safety committees. These committees are able to monitor the 
experiments on a day to day basis. At the same time internal 
safety committees obviate the concern for unnecessary disclosure 
of proprietary information which sometimes causes problems with 
an IBC. We believe that these safety committees are a good 
example of a useful addition to IBC review that can improve the 
overall process of monitoring. 
General safety committees are industry practice now 
and, I believe, are useful not only to supplement the IBC review 
as indicated above but are also valuable in assessing and 
controlling safety risks of a more general nature. Such 
committees might typically review the use of flammable solvents, 
the design and safety of particular items of equipment, fire 
safety, emergency procedures and similar safety issues. Because 
of our view of the safety of rDNA research per se, many of us see 
the conventional safety issues as the more significant ones to be 
assessed and controlled. 
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