4. The Guidelines are inadequate in their require- 
ments tor worker education regarding the hazards 
of recombinant DNA molecules. They state simply 
(a) (p. 33053). that the NIH has a contract ... to 
develop "minimum standards for training partici- 
pants in recombinant DNA research;" and (b) 
(p. 33085, IV-A-4-m- (1) ) , that the principal 
investigator shall "make available to the lab- 
oratory staff copies of the approved protocols 
that describe the potential biohazards and the 
precautions to be taken." Both provisions 
ignore other than research personnel who are 
exposed. Any my experience with industrial 
training programs and provision of data sheets 
is that they are inadequate and incomplete. 
5. The Guidelines place primary responsibility 
(p. 33085, IV-A-2-a-c) for key technical and 
procedural decisions in the hands c-f the 
Institutional Biosafety Committee: to approve 
recombinant DNA research projects; to approve 
reduction in containment levels; to monitor 
compliance with the Guidelines;, and to review 
and approve emergency plans covering accidental 
spills . 
This situation is analogous to the allocation 
to the states of responsibility for monitoring 
and enforcing industrial compliance with OSHA 
standards. Such a scheme has proved to be 
disastrous for Labor because of local conflicts 
of interest and incompetence. 
Given the unknown nature of the effects of exposure to recom- 
binant DNA material, and the failure (and in fact, inability , given 
the current state of knowledge) to provide a mechanism for the 
adequate protection of the worker, the risks of recombinant DNA/ 
research would seem to far outweigh the benefits. 
And what are the benefits? The postulated benefits of recom- 
binant DNA research include the correction of genetic defects; the 
prevention of cancer; the treatment and possible prevention of 
diabetes; the prevention of heart disease; and the satisfaction 
of the world's nutritional needs. But other less hazardous, less 
expensive and more readily available means to the same ends exist. 
1. Identifiable genetic defects afflict a small 
percentage of the U.S. population. Genetic 
counselling and amniocentesis exist as pre- 
ventive measures. 
2. Seventy to 90% of cancer is environmentally 
induced. Of these cancers at least 40% are 
occupationally induced. Elimination of toxic 
exposures at the workplace; change in dietary 
and smoking habits; reduction in air and water 
pollution; and routine screening procedures 
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