highlighting the disincentives in the current system of 
enforcement for researchers and IBCs to report accidents or 
violations • 
These proposed revisions exacerbate the conflicts of 
interest inherent in self-regulation by shifting more of 
the responsibility for setting containment levels to IBCs which 
are even closer than NIH to the scientists with the greatest 
interest in pursuing the research. At the same time that the 
proposed revisions increase the conflict of interest problems 
they decrease the accountability of the Directors and the IBCs 
by allowing more discretionary case by case decisions — 
^.e. , exemptions, exceptions and lowering of containment levels. 
This trend should be reversed by having the Office of 
the Secretary of Health, Education and Welfare assume more 
supervisory responsibility for the enforcement of the guidelines. 
This does not mean that HEW should become directly involved 
in regulation. However, in the absence of Federal legislation 
on R-DNA, HEW could make NIH and the IBCs more accountable 
by providing broad standards to define the limits of their 
discretion. 
First such standards should define the circumstances under 
which the guidelines can be revised. In particular, the 
standards should require that changes in the guidelines be 
tied to the results of a risk assessment program. HEW should 
also provide that exceptions to the guidelines can only be 
granted when necessary for a risk assessment experiment and 
[A-201] 
