seriousness of the experiments allowed at P2 containment 
levels in the proposed revised guidelines. § IV-A-3 as 
written will only result in increased institutional 
pressure to dergulate experiments to a level where a 
biological safety officer is not needed. 
(3) The biological safety officer should be an exclusive 
full-time position. Under the proposed revisions, the 
biological safety officer need not be a new member of 
the institutional staff. Academic taboos and institutional 
hierarchies would reduce the effectiveness of the position 
if the person holding it has other institutional 
responsibilities . 
(4) At least one member of the IBC should be a non-doctoral 
person from a laboratory technical staff. § IV-A-2 
recommends this; we believe it should be a requirement. 
(5) The local IBC should have the authority to raise 
as well as make single step reductions in the containment 
levels for some experiments with purified DNA and 
characterized clones containing recombinant DNA molecules. 
(S IV-A-2-b) . This may be appropriate at medical 
centers where a large number of hospital patients who 
would be especially susceptible to any breach of 
containment are in close proximity to the laboratories. 
Another case where a local IBC may want to set more 
[A-203] 
