16 
would not vary from location to location, and therefore the assessment of risks 
involved in recombinant DMA work should best be performed by a single body. 
My experience on an IBC leads me to believe that none of these committees has 
the competence, time, or resources to do adequate risk evaluation. 
Members of IBCs are primarily going to be employed in other capacities or 
have other substantial responsibilities to their families, communities, and the 
like. Members of the IBCs are not themselves full-time personnel involved in 
risk assessments, laboratory inspection, training program certification, or any 
of the other kinds of substantially time-consuming activities for which the 
Guideline revisions purport to give them responsibility. For most committee 
members, this is an "add-on" activity, although one which may be undertaken 
with the highest considerations for its seriousness and public importance. 
Nonetheless, virtually none of us on the University of Washington IBC, other 
than DNA researchers themselves, on a regular basis go to DNA laboratories to 
ascertain whether the Guideline procedures are being followed, sit in on training 
programs, and make judgments as to the competence and training of individual 
research personnel, etc. 
As a result, although the Guidelines require that the institution assume 
responsibility for assuring compliance (section IV-A-l-d) , in fact most insti- 
tutions and their IBCs are unable to do so; even if they were to attempt to carry 
out this function, how will the NIH know that the institution is adequately 
fulfilling it? Administratively, this situation is central to the Guidelines, 
and yet it is essentially a set of "paper platitudes." Let me provide several 
examples from my own IBC experience. Under the current regulations, it is 
forbidden to eat food in a P-2 laboratory. Yet, students of mine have dropped 
in at P-2 laboratories at noontime and found personnel eating lunch at the 
[ 329 ] 
