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carry out. If the University of Washington is at all representative, it must 
be said that we have virtually no resources at our disposal to conduct such 
activities, we have no personnel under our direction that we can require to 
assist us in performing such functions, and essentially no budget for our 
operations. 
Indeed, the NIH revised Guidelines are remiss in requiring such significant 
responsibilities of the IBCs and not requiring adequate fiscal support for 
them. At the very least, the NIH should require that a percentage of the 
overhead which is charged on DNA research proposals to the NIH be earmarked 
for operations of the IBC, and that the IBC be provided with adequate budgetary 
and administrative support in carrying out these responsibilities, as a 
condition of institutional funding by the NIH. It is true that these concerns 
have been raised to the NIH before, but the Director's comments (FR 33065) 
on this regard do not solve the problem. He has assumed that because the 
government research grants contain an overhead factor, therefore the NIH is 
already paying for the operation of such committees, but I can assure him, 
and the hearing panel in general,, that the committees never see such funds, 
and that there are severe budgetary limitations on the IBCs in carrying 
out the functions expected of them. 
The University of Washington IBC has been carrying out many of the functions 
which the guidelines envision, however. Among these are development of 
procedures for certifying actual laboratories as meeting the levels of 
physical containment claimed for them; participation in the development and 
certification of training programs to insure that researchers carrying out 
recombinant DNA work are aware of what the regulations require of them and 
have the capabilities to carry out those requirements; passing on the 
qualifications of specific researchers to actually carry out the research 
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