23 
An institutional biohazards safety officer should be required to be on 
an IBC or to work in close association with i-t (even if only P-1 and P-2 work 
is being performed at the institution). As noted above, the way that the 
revision contemplate constituting IBCs, virtually none of the actual mem- 
bers (other than perhaps the DNA researchers themselves) will have the exper- 
tise nor the time, etc. , to actually ascertain complaince. It is inconsistent 
to require certain levels of due care (the physical safeguards) and to require 
that the IBCs assure compliance with this, without also requiring that the 
IBCs contain the competence to do so. 
The ORDA is required (in section IV-B-3-a-(8)) to review the membership 
of the IBC. However, the Guidelines in no way provide any criteria for 
ORDA in terms of carrying out this function, nor do they indicate what kinds 
of sanctions, if any, ORDA can bring to bear against an institution which 
has a committe which is not deemed in compliance. This section of the 
Guidelines should be elaborated in some additional detail. 
The Guidelines themselves contain virtually nothing on RAC membership, 
although it is recognized as a problem (FR 33066) . It is true that the 
Director acknowledges that the RAC is to be primarily a technical committee, 
but its functions actually go beyond this to encompass matters of public 
policy. (See Director's discussion, FR 33067-8.) As a result, the NIH should 
either have two committees to advise it (one as a technical committe and the 
other to examine non-technical policy questions) or the RAC should be 
definitively re-constituted in order to deal more effectively, and in a 
representative fashion, with the broader issues of social responsibility and 
control which are presented by the public policy aspects of its decisions. 
If the latter instance is followed, clearly additional public members need 
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