104 
1 them, they provide for sanctions that are inadequate to 
2 ensure compliance. To wit, page 33087 , "noncompliance 
3 may result in suspension, limitation, or termination of 
4 financial assistance for such projects." 
5 Two, the guidelines do not apply to industry. 
5 To compound this error of omission is a notorious problem 
7 in industrial research of large-scale production, and as 
g commercial use increases, production will increase, job 
9 speed-up will increase, accidents will increase, and 
10 hazardous exposures will increase. 
11 Three, the guidelines are inadequate in their 
12 specification for biological monitoring or medical surveil- 
13 lance, page 33084. The institution would be given respon- 
14 sibility for the determination, "in connection with each 
15 project, the necessity for medical surveillance of recom- 
10 binant DNA research personnel." Thus, A, the institution 
17 may determine that medical surveillance is unnecessary; 
18 B, the stipulation is for research personnel only. It 
19 ignores maintenance and janitorial staff, and it ignores 
20 the families of the exposed workers, who in many cases 
2 1 may also suffer the effects of exposure. C, the require- 
22 ments are too nonspecific and leave too much to the 
23 discretion of the individual institution. 
24 Four, the guidelines are inadequate in their 
25 requirement for worker education regarding the hazards of 
[196] 
