10 
Probably the most significant aspects of the guideline revisions, in 
terms of public policy and administration, is the delegation of basic 
regulatory authority from the NIH to the IBCs. NIH is clearly within its 
authority to mandate certain standards about the composition and functioning 
of the IBCs, and I believe that the Guidelines are inadequate in this 
regard. (See FR 33085.) I have participated in research activities 
investigating the composition of existing IBCs. Others here today will 
testify in greater detail about these findings, but for now let me state 
that most IBCs, if not all, are hopelessly demographically skewed. They 
are totally non-representative of the communities whose safety and interests 
are concerned. They are overwhelmingly (and in some cases exclusively) 
male, white, graduate degree holding, and the like. I make this accu- 
sation against my own IBC, although we are composed in a much better 
fashion than committees at most other institutions. 
The Guideline revisions would perpetuate this situation. They require 
that committees contain members from "disciplines relevant to recombinant 
DNA technology, biological safety, and engineering." No other disciplinary 
areas, and no areas whatsoever of human experience that cannot be categorized 
by some academic disicpllne, are required at all on a committee which is 
supposed to make determination about public health and safety. The Guide- 
lines only "recommend" that the IBC also include "members knowledgeable 
about such matters as applicable law, standards of professional conduct and 
practice, community attitudes, and the environment" as well as "at least one 
member [to] be a nondoctoral person from a laboratory technical staff." The 
only other requirement is that "at least one member shall not be affiliated 
with the institution" but for membership on the IBC. I submit that this is 
wholly insufficient. First, there are other areas of expertise which are 
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