members or Ad Hoc Committees, be employed and that their evaluations continue 
to be exposed to public scrutiny. The use of workshops, special studies and 
open, publicized meetings of the Advisory Committee are sound and appropriate 
procedures to reevaluate containment levels of host-vector systems. 
(3) Responsibilities of Institutional Biosafety Committees (IBC) 
In testimony last year before the Kennedy Subcommittee hearing on DNA 
recombinant research, we suggested that the institutional biosafety committees 
should have a leading role in assessing individual laboratories as to the adequacy 
of safety procedures, the appropriate levels of physical containment and bio- 
logical containment, the provision of educational materials and the review of 
experimental design. We support these developments in the revised guidelines 
and reiterate that the local’ groups are more knowledgeable of the strengths 
and weaknesses of any scientific colleague than would be possible with govern- 
mental review agencies. This procedure has a proven history in protecting 
human subjects in medical centers. 
Increasing authority to the IBC carries with it the responsibility of 
assuring that this committee has the relevant scientific expertise and public 
(non- institutional) representation. We suggest that the NIH Advisory Committee 
may want to consider in its further development of policies, recommendations 
on the composition of the IBC to ensure that it is capable of fulfilling its 
responsibility. As we pointed out in the Stevenson hearing the above recom- 
mendation carries with it an obligation of NIH to bear some financial costs 
for appropriately transferring Federal responsibility to IBC's. 
(4) Authority of the Director of NIH to Make Exceptions 
We are firmly convinced that it is essential to continue to provide authority 
of 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, since the development 
