confusion and disrespect in the implementation of the 
Guidelines. A uniform set of Guidelines is a necessity 
for the safe conduct of recombinant DMA research. No 
empirical justification for choosing between containment 
level combinations is offered and this approach should not 
be accepted without a full explanation. 
Finally, provisions for the enforcement of the 
Guidelines are inadequate. NIH should enforce the 
Guidelines and monitor its grants for recombinant DNA 
research. Yet, the revised Guidelines delegate responsibility 
for inspection, oversight and even choice of containment 
levels to the Institutional Biohazard Committees. This we 
believe is an improper abrogation by NIH of its duty to 
administer its grant program. Enforcement of the Guidelines 
cannot be left to the institutional beneficiaries of the 
grants. There is an obvious conflict of interest. Instead, 
NIH should allocate sufficient funds towards the administration 
of its grant program providing for personnel and equipment to 
inspect grantees. If NIH will sponsor this research, it 
has the duty to ensure that recipients of grants comply 
strictly with the rules. In a broader perspective, 
legislation is required to make the Guidelines applicable 
to non-NIH grantees and to impose effective penalties 
for non-compliance. New York State recently 
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