oversight responsibility given to the IBC's. It is the duty 
of NIH to administer a grant program and to insure compliance 
with the Guidelines. This role can not be delegated to its 
grantee institution without raising serious conflicts of 
interest. 
The rationale for switching physical and biological 
containment levels is not adequately explained. The method for 
quantifying containment levels is unclear and could give the 
impression that the decision to allow this was based on 
researcher ' s convenience rather than on empirical analysis. 
Similarly , the rationales for lowering containment levels 
for shotgun experiments and exemptions from the ten liter limit 
are unclear. In the latter case, once again, ecological 
factors are ignored as this limitation only applies to 
recombinant organisms known to make "harmful products” (p. 33107) . 
"Harmful products" must not be defined too narrowly. The proper 
questions to ask in assessing ecological harm include the 
following: If introduced into different environments would it 
cause changes in species composition, would it alter the existing 
balance of plants and animals , would it outcompete a natural 
resident of a niche? These are the factors that must be 
considered in assessing harm. 
- 6 - 
[ 345 ] 
