Page 3 
Coalition 
to develop "minimum standards for training participants in recombinant DNA 
research " (p. 33053), once again other worker populations such as custodial, 
maintenance, and janitorial employees are overlooked. This lack of attention 
to the needs of non-research personnel for education is also illustrated in 
the directive to the principal investigator who shall "make available to the 
laboratory staff copies of the approved protocols that describe the potential 
biohazards and the precautions to be taken." (p. 33085 IV-A-4-m-[l] ) Further, 
The vagueness of some terminology can lead to ineffectiveness of collected 
data. For example, experience with industrial Material Safety Data Sheets, 
which in theory indicate the biohazards of exposure, reveals that it is nec- 
essary to require that these "protocols" specify both acute and chronic ef- 
fects; not only those known with certainty but also those strongly suspected. 
V. E meAgenct/ Spitla 
The Guidelines do not adequately treat the courses of action in the event 
of emergency spills. It is mandated that the Biological Safety Officer shall 
develop "emergency plans for dealing with accidental spills and personnel con- 
tamination..." (p. 33085 IV-A-3-b) . Also that the Institutional Biohazard Com- 
mittee shall "review and approve emergency plans covering accidental spills..." 
Cp. 33085 TV-A-2-d) . Such directives permit utilization of varying levels of 
expertise among members of the IBC, et al. Only specific and detailed in- 
structions in the Guidelines for emergency spills can overcome the problems of 
uneven expertise and institutional pressures. 
VI. Tn&titationaZ SiohazAAd CormUXtzz 
The Guidelines omit representation of workers in their specifications 
for the constituency of the IBC. In addition, representation of experts 
trained in the fields of worker and public health is inadequate. 
[A-331] 
