8 
are being taken at the institution to protect the general environment and 
community from potentially hazardous material" (p. 187). Clearly the 
"adequacy" of safeguards is a determination which is heavily value-laden. 
Yet, as I will maintain below, the Guidelines do not require adequate in- 
stitutional mechanisms to insure that these value issues are resolved through 
the participation of the only persohs who can legitimately provide insight 
into them — the general public which is affected. 
In other places, the NIU is confused about the differences between risk 
and safety. For instance (FR 33084), there is the statement that "safety 
involving recombinant DNA molecules depends primarily on the individuals 
conducting the research activities." What the revised Guidelines apparently 
mean is that risks involving recombinant DNA research depend on the indi- 
viduals conducting the research and the manner in which they conduct it. 
Safety is not their province alone; safety is a concern of the larger 
community, and in its determination the researchers have an important 
role to play in enlightening the local public as to some of the relevant 
factual information which may go into that determination. 
On the same page in the Guidelines appears the sentence "motivation and 
good judgment [on the part of the researchers] are the keys to protection 
of health and environment." This statement, which introduces the Guideline’s 
section on "Roles and Responsibilities," raises significant value issues. 
It is clear from experience under the existing Guidelines that — expressions 
and acts of scientific collegiality to the contrary notwithstanding — research 
in this area is intensely competitive and research groups are vying 
with each other for prestige and prizes. These are significant motivations 
of the researchers which the guidelines ignore in relegating to the researchers 
and to the institutional biohazards committee (which are so largely populated 
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