Page 6 
Coalition 
1/7. EmeAgzncy Pfiocddu/ieA and. Cleanup ofi Sprite 
According to the proposed revised guidelines, the IBC's will be 
responsible for reviewing and approving emergency plans for accidental 
spills and personal contamination (p . 33085, Col 2). The development of 
detailed emergency procedures is not required. 
RECOMMENDATION : Detailed emergency procedures, which take into account the 
organisms being worked with, should be drawn up by the bio- 
hazards officer in conjunction with the local biohazards 
committee. The plans should be submitted to the central 
agency responsible for keeping records of certification of 
laboratories and training of personnel, and medical and 
monitoring records. 
I/I I. Hoik AA*e64me.n£ 
The guidelines do not spell out the relation between the risk assess- 
ment experiments for which contracts are being let by NIH and the responsi- 
bility of the NIH advisory committee (RAC) for determining the potential 
risks posed by specific procedures (p. 33086, Col. 2). In the past, this has 
often meant that the advisory committee has determined the level of potential 
risk of a particular procedure through discussion rather than through experi- 
ment . (For example, the level of risk posed by E. coli bacteria programmed 
to make rat growth hormone and rat insulin was determined by the RAC at its 
April, 1978 meeting on the basis of rule-of-thumb calculations, not on the 
basis of experiment) . Because risk assessment experiments are not required 
to accompany innovations in the recombinant DNA field, knowledge of the full 
implications of the technology lags far behind developments in the field. Yet 
caution and scientific canon would seem to have been sidestepped, for example, 
unnecessarily, due to hastening of proposed revisions to the guidelines before 
obtaining the data of the Martin-Rowe risk assessment experimentation. 
RECOMMENDATION ; It is necessary that a comprehensive program of risk assess- 
ment be integrated into a general policy framework. Specif- 
ically, such a program should require that risk assessment 
keep pace with new developments and precede all larger-scale 
applications and precede all procedures potentially involving 
release of organisms containing recombinant DNA into the en- 
vironment . 
[A-288] 
