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governmental review agency. This procedure has a proven 
history in protecting hunan subjects in medical centers. 
Increased authority to the IBC carries with it 
the responsibility of assuring that this committee has the 
relevant scientific expertise and public -- that is, non- 
inst itutional -- representat ion . We suggest that the NIH 
Advisory Committee may want to consider in its further 
development of policies, recommendations on the composition 
of IBC 1 s to ensure that it is capable of fulfilling this 
responsibility. As we pointed out in the Stevenson hear- 
ings, the above recommendation carries with it an obligation 
of Win to bear some of the financial costs for appropriately 
transferring federal responsibility to IBC's. 
The fourth point deals with the authority of the 
Director to make exceptions. We are firmly convinced that 
it is essential to continue to provide authority to the 
Director of NIH, with appropriate study review, to make 
exceptions to the guidelines. First, experience has shown 
that this authority is exercised with care and only after 
careful review. Second, after the initial guidelines, one 
cannot anticipate all the advances and opportunities and 
new information on natural gene transfers or risk assessments. 
For example, it is not unlikely that Bacillus punul is and 
Bacillus s u b t i 1 i s may exchange genetic information naturally. 
If this could be demonstrated such recombinant DMA 
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