Page 3 
Coalition 
t 
ards, are specified. Biohazards officers are only required for institu- 
tions with P3 and P4 facilities. This arrangement allows considerable 
scope for error, especially at smaller institutions where conceivably no 
staff person would be qualified to make an independent judgment on train- 
ing and degree of physical containment . 
RECOMMENDATION ; Facilities, and the training of laboratory workers in those 
facilities should be certified prior to commencement of work 
involving experiments covered by the guidelines. Each insti- 
tution should have a biohazards officer responsible for the 
certification process, who would report to the biohazards 
committee. A central registry of facilities and workers in 
those facilities should be maintained. 
V . LabeZting ofi OfLgani&mA, MotyLtorUng, and Lzgal L-ia.bZltty 
The proposed revised guidelines mention medical surveillance (33065, 
Col. 2; 33084, Col. 3) but the nature and extent of medical surveillance 
appears to be left entirely to the discretion of individual institutions. 
No provision is made for a central clearing house for keeping records of 
personnel, accidents, incidence of illness, or the degree to which organisms 
containing recombinant DNA are being contained. This means that there will 
be great difficulty in establishing legal liability in cases where illness 
appears to be linked to recombinant DNA activities. A general policy ques- 
tion which should be addressed is whether it is justifiable for any poten- 
tially hazardous activity to continue until an effective surveillance system 
has been articulated in relation to the legal system. 
RECOMMENDATION ; Effective techniques for monitoring recombinant DNA and 
the organisms- containing it need to be developed. A bio- 
hazards officer should be appointed for each institution 
and should be responsible for monitoring, medical sur- 
veillance, and for keeping records. A central office (poss- 
ibly within CDC, NIOSH, or EPA) needs to be established to 
maintain accurate records of personnel working with recom- 
binant DNA, the incidence and severity of work-related ill- 
ness, and of the escape of organisms containing recombinant 
DNA from physical containment. 
[A-287] 
