12 
1 The section of the guidelines dealing with 
2 certification of host-vector systems is an example of 
3 the problematic ambiguity. The guidelines state that 
4 certain new host-vector systems, "may not be used unless 
5 they have been certified by NIH." But there is no 
6 indication of what office within NIH would supply the 
7 certification. The person seeking certification does 
8 not know if he or she is free to use the host-vector 
g system after approval by the Recombinant DNA Advisory 
IQ Committee, or if they must wait for approval of the 
11 NIH Director. Just this ambiguity was cited by the 
12 University of California at San Francisco to explain 
13 their violation of the existing guidelines, yet it 
14 has not been cleared up in the present draft. 
15 An example of the contradictory nature of 
1g the various documents in the Federal Register package 
17 is a section dealing with exceptions from prohibited 
18 experiments. The Director's decision document indi- 
19 cates that the rationale for allowing exceptions is to 
2Q provide for experiments for which there are compelling 
21 social or scientific reasons. Yet the guidelines 
22 themselves merely indicate that weight will be given 
23 in the decision-making process to "both scientific and 
24 social benefits and to potential risks." Clearly, the 
25 standard for excepting experiments is different in 
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