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Coalition 
II . EnvZn.ome.ntaZ MoniZonZng 
The proposed revised Guidelines provide no stipulations for environmental 
monitoring for recombinant DNA materials. Indeed, a mechanism for monitoring 
for presence in the air does not yet exist for much of recombinant DNA material. 
III. ScoZogZcaZ MoYiiA.oJu.Yiq and MecLLdaZ SuAveZZZance 
The Guidelines are inadequate in their specifications for biologic monitor- 
ing and medical surveillance. The institution would be given responsibility for 
the determination "in connection with each project, the necessity for medical 
surveillance of recombinant DNA research personnel..." (p. 33084 IV-A-l-e) . 
Such a program "might include, for example, records of agents handled, active 
investigation of relevant illnesses acquired by recombinant DNA research per- 
sonnel and the maintenance of serial serum samples". Such wording offers the 
institution the option of determining that there is no need for medical sur- 
veillance. 
The lack of specificity of the Guidelines’ language in this area of pro- 
tection of employees may well exclude some worker populations. Stipulations 
for "research personnel" does not provide for members of the custodial, main- 
tenance and janitorial jroy# s. Often these latter groups are at special risk 
because of their lack of knowledge of their conditions of exposure. Further, 
if each institution is given responsibility for each project under its aegis, 
the variability in program development and implementation among diverse 
institutions would provide for the exposed worker unequal protection under the 
law. 
II/. WonkeA Education 
Guideline requirements for educating workers about the potential hazards 
of working with recombinant DNA materials are inadequate and vague. While it 
is stated that the NIH has a contract with the American Society for Microbiology 
[A-330] 
