At the same meeting Dr. Curtiss noted: 
[T]he intestinal environment becomes much more 
conducive to conjugational plasmid transfer if an 
individual is receiving antimicrobial therapy. 
The pH, Eh (oxidation-reduction potential), and 
volatile fatty acid concentration then change to 
values more favorable to conjugational events. 
There is also a decrease in drug-sensitive normal flora; 
the resultant void is filled by the newly introduced 
strains and drug-resistant flora which possess 
conjugative plasmids. For these reasons, the NIH 
Guidelines for Recombinant DNA Research specify that 
individuals cannot conduct recombinant DNA research 
during, and for seven days following the cessation of, 
antimicrobial therapy. (F: 672) . 
We urge the NIH to reinstate the antibiotic provision of the 
September 27, 1977 proposed guidelines. 
We recommend that NIH set up a rigorous epidemiological 
program to monitor and track all laboratory workers engaged in 
recombinant DNA research. The guidelines (§ IV-A-l-e) leave 
the question of surveillance at the discretion of the institution 
doing the research (p. 33084) . NIH funding of recombinant research 
provides an opportunity to study potential risks. This opportunity 
to monitor the health of occupationally exposed laboratory 
personnel, and thereby collect data to evaluate these risks, 
should not be lost. Such an effort is a necessary element of 
any risk assessment program. 
Finally, the sanctions provided for non-compliance with 
the guidelines (§ IV-D-1) are inadequate. By making the 
draconian measure of grant denial. the only sanction, NIH creates 
a great disincentive to reporting and effective enforcement. 
Lesser sanctions should be provided so that violations will 
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