105 
1 recombinant DNA molecules. They state, simply, A, page 
2 33053 , that the NIH has a contract to develop, "minimum 
3 standards for training participants in recombinant DNA 
4 research," and B, page 33085 , that the principal 
5 investigator shall, "make available to the laboratory 
5 staff copies of the approved protocols that describe the 
7 potential biohazards and the precautions to be taken." 
g Both provisions ignore other than research 
g personnel who are exposed, and in my experience, indus- 
10 trial training programs and the provision of material 
11 safety data sheets is that they are inadequate and 
12 incomplete. 
13 Five, the guidelines place primary responsi- 
14 bility, page 330 ^ 5 , for key technical and procedural 
15 decisions, in the hands of th€; Institutional biosafety 
15 committee. These include the approval of recombinant 
17 DNA research projects, the approval of reduction in con- 
18 tainment levels, the monitoring of compliance with the 
19 guidelines, and the review of approval of emergency 
20 plans covering accidental spills. This situation is 
21 analogous to the allocation to the states of responsi- 
22 bility for monitoring and enforcing industrial compliance 
23 with OSHA regulations. Such a scheme has proved to be 
24 disastrous for labor because of local conflicts of 
25 interest and incompetence. 
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