16 
1 should represent the health deoartment of the local 
2 government -- again, selected by that local government. 
3 The remainder of the nonaf f il iated members should be 
4 persons who could be reasonably expected to represent 
g the interests of the community. That, again, is the 
g HSA language. 
1 The membership ratios that EOF suggests are 
g necessary to insure that IBC's will satisfactorily per- 
g form their oversight and regulatory roles. It is well 
IQ known from our sad experience of medical licensing and 
H disciplinary boards, and from the events surrounding 
12 the violations of the recombinant DNA guidelines at 
13 Harvard Medical School and U.C. San Francisco, that 
14 peer review has not provided adequate public protection. 
15 The proposed guidelines' requirement for one 
16 nonfacility member does not address this issue sufficiently 
17 There is no provision that this individual at all represent 
18 the public interest. It would be very easy for a facility 
18 to just, appoint another recombinant DNA scientist from a 
2Q neighboring institution, and yet fulfill the guidelines' 
21 requirement for a nonfacility member. 
22 burning to confidentiality, FDF maintains that 
23 all IBC meetings should be announced and open to the public 
24 All MUA's and project registrations from institutions that 
25 must comply with the guidelines should also be available to 
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