VII. ADMINISTRATIVE DISCRETION AND DECENTRALIZATION 
The same philosophy which has prompted the proposed 
reduction in containment levels is also the basis of the 
proposed increased reliance on Institutional Biosafety 
Committees (IBCs) and increased discretion for them and 
the Director of NIH. According to the Director, the lack 
of information about risks warrants looser administration 
of the guidelines . 
Two years ' experience with the guidelines 
has offered valuable tutelage in the limits 
of external (Federal) control of laboratory 
experimentation . . . Without a base [of 
information about risks] , conventional 
regulation is difficult at best, and at worst 
can be preposterous. 43 FR at 33045. 
Instead of "traditional regulation" NIH proposes a form of 
enforcement which institutionalizes conflict of interest 
and provides even less accountability for the Director of 
NIH and the IBCs than the previous guidelines. 
Dr. Frederickson himself has recognized the problems 
of having NIH both promote and regulate recombinant research 
and recommended that new legislation relieve NIH of regulatory 
responsibility.—^ There have already been two reported 
cases of violations of the 1976 guidelines. In both instances, 
laboratories of researchers connected with the formulation of 
the guidelines were involved. The NIH was unwilling to impose 
serious sanctions against the offending parties, thus 
22 / Recombinant DNA Research and Its Applications , Oversight 
Report by the Senate Subcommittee on Science, Technology, 
and Space, August 1978. 
[A-200] 
