11 
clearly as important as engineering and the rest— for example, the policy 
sciences. Secondly, there are general areas (which I would not call disci- 
plines) which are essential in any attempt to determine safety — community 
leaders who are in touch with grassroots attitudes, for example, should be 
mandated on IBCs, environmental groups which have been diligent in public 
interest protection of the environment are in the best position to present 
those concerns for an.IBC's deliberation, etc. Third, a "non-doctoral 
person" could be a graduate student under the tutelage and presumably the 
direction of a DNA principal investigator; the guidelines should clearly 
mandate IBC membership by a laboratory technician or other working person. 
Fourth, requiring one member of the IBC to be unaffiliated with the 
institution smacks of tokenism. Every large institution has dozens of persons 
around who maintain no formal affiliation, and draw no salary from it, but whose 
social and professional relationships are so intertwined with those of the 
institution's administrators as to have an identity of viewpoints. The 
discussion by Director Fredrickson (FR 33065) of this matter does nothing to 
assuage my fears in this regard. Finally, the guidelines should mandate 
membership on the part of a public health off ical (if the local authorities, 
of course, agree) rather than just suggesting cooperation; under our con- 
stitutional system, the fundamental responsibilities for protection of the 
public health and safety ("the police power") reside with the state, which 
may have delegated such responsibilities to local jurisdiction. In no way 
can the NIH Guidelines usurp this authority, and indeed they should recognize 
it fully in the provisions for IBC membership. Membership by local governmental 
officials on the IBC would facilitate recognition of the largely political 
character of some of the IBC decisions. Let me emphasize that I see this 
as a positive factor, not something to be avoided or circumvented. 
[ 324 ] 
