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programs (this is especially important in regard to the more risky types 
of experiments, such as those proposed at a P-3 level). 
(2) Institutional policies beyond the guidelines . Section IV-A-2-a 
of the Guidelines (FR 33085) defines the responsibilities of the IBC as to 
"review and, if in compliance with the NIH Guidelines, approve the initiation 
of all proposed recombinant DNA research conducted at or sponsored by the 
institution receiving NIH funds for any recombinant DNA research." This 
is an expansion of the earlier statement (section IV-A-2) that "the 
principal functions of the IBC are to review and oversee all recombinant DNA 
projects and to advise the institution and ORDA whether the proposals and 
the research comply with the NIH guidelines." However, none of this 
language expresses NIH recognition, nor provides notice to investigators 
of the possibility that an instituion may institute policies in addition to, 
or going beyond the requirements of, the NIH guidelines. NIH should recognize 
these institutional prerogatives and should indicate its willingness to 
respect the exercise on the part of the institution of policy considerations 
which go beyond the letter of the Guidelines. This should be done to provide 
notice to the institutions and to the investigators, and is in accord with 
the introduction to section IV which acknowledges that the Quidelines 
"will never be complete and final, since all conceivable experiments involving 
recombinant DNA cannot be foreseen" and also that "the guidelines cannot 
anticipate every possible situation" (FR 33084) . 
I would suggest that the language of (ii) be changed to something along 
the lines of the following: "review all proposed recombinant DNA research 
conducted at or sponsored by the institution receiving NIH funds for any 
recombinant DNA research to ascertain compliance with the NIH Guidelines and 
with any institutional rules, policies, guidelines which may have been adopted 
to regulate such research, and on the basis of such review, vote its approval. 
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