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1 per year. 
2 Two, since the effects are not known, accurate 
3 biological monitoring for the effects of the exposure to 
4 recombinant DNA material is impossible. Latency periods 
5 are unknown and unpredictable. Thus, the establishment 
6 of cause and effect, and ultimate prevention of permanent 
7 adverse health effects are impossible. 
8 Three, adequate techniques for environmental 
9 monitoring for recombinant DNA molecules do not exist, 
10 so that with neither accurate biological monitoring nor 
11 adequate environmental monitoring, the ascertainment of 
12 the level of worker exposure to recombinant DNA material 
13 is impossible, and thus an assessment of the risk is 
14 impossible. 
15 Four, contrary to the statement in the July 
16 28th Federal Register, page 33065, that "OSHA standards 
17 a nd procedures apply to most institutions," OHSA regula- 
18 tions do not apply to university and federal research 
19 laboratories, where much of the recombinant DNA research 
20 is being done. Thus, many of the workers who face 
21 hazardous and unpredictable exposures to recombinant 
22 DNA molecules are not protected by OSHA, and they are 
23 not protected under the proposed revised NIH guidelines. 
24 One, the "guidelines" are simply that, 
25 guidelines. They do not have the force of law behind 
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