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1 delegation of authority in the guidelines, because as I 
2 say, I feel this is quite significant. 
3 The response of the NIH in the guideline 
4 revisions, I believe, has been to propose to enhance 
5 the responsibilities of local institutions rather than 
g to make sure that there is a balance or safeguard against 
7 some of the kinds of irresponsibility which have occurred 
8 in the past. At this time I do not believe that sweeping 
g delegation of authority for initial approved experiments 
10 should be made to the IBC's, both because they are 
11 unrepresentative, and because, as I hope I have time 
12 to point out, in many ways they are not going to be 
13 competent as envisioned in the guidelines, to carry out 
14 the responsibilities envisioned for them. 
15 For example — to skip ahead briefly — most IBC's 
16 are composed of people who are donating a little bit of 
17 their time, part-time, a couple of hours a month, to this 
18 activity; and no one, except perhaps actual DNA researchers 
19 themselves, have the time, or energy or competence / to actually 
20 inspect the laboratories, or to monitor on any systematic 
21 basis the standards of care that are followed there. 
22 This is a free kind of donation of services on the 
23 part of most people who hold other jobs and have other 
24 demanding responsibilities to fanily and to community, as 
25 well as to professions. But the whole question of the most 
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