DNA/11 
surveillance is ordered by NIH, then NIH should further specify the 
nature of the program required. If NIH determines that surveillance 
is not necessary, NIH should be required to present its reasons in 
writing to the IBC for the public record. This statement should be 
made available by the institution to those workers involved in the 
activity in question. 
IV-A-2. PRG-NIH requirements for membership on IBCs do not 
insure that these committees will satisfactorily perform their over- 
sight and regulatory roles. PRG-NIH essentially calls for peer re- 
view of recombinant DNA activities. Experience with Institutional 
Review Boards^-, medical licensing and disciplinary boards and the 
handling of violations of the existing recombinant DNA "Guidelines" by 
the biohazard committees of Harvard Medical School^ and the University 
of California at San Francisco 3 , demonstrate that peer review does 
not adequately protect the public. The collegial instincts of peer 
groups, the lack of regulatory and oversight experience of most 
academic personnel, and the desire of institutions to avoid negative 
publicity combine to make the performance of peer review groups com- 
pletely unsatisfactory. PRG-NIH* * s attempt to solve this problem by 
^ The National Commission for the Protection of Human Subjects of 
Biomedical and Behavioral Research. Report and Recommendations 
Institutional Review Boards . U.S. Department of Health, Education 
and Welfare. DHEW publication No. (OS) 78-0009. 
* Report of Ad Hoc Committee on Recombinant DNA at Harvard Medical 
School, April 18, 1978. 
3 Wade, Nicholas. Recombinant DNA: NIH rules broken in insulin gene 
project. Science 197: 1342-1345. September 30, 1977. 
[A-346] 
