DNA/12 
mandating that one IBC member cannot be affiliated with the institu- 
tion completely fails to eliminate the problems of peer review. The 
PRG-NIH requirement clearly enables institutions to appoint zealous 
recombinant DNA researchers to IBCs, just as long as they work some- 
where else. In addition* one non-af filiated member in a sea of paid 
university employees does not provide the balance and courage needed 
on an IBC. 
EDF therefore maintains that the following membership ratios 
be mandated for all IBCs. One third of the membership of each IBC 
should be composed of individuals who have not been affiliated with 
the institution for at least one year prior to their service on the 
IBC. At least one of these individuals should be a non-doctoral person 
from a laboratory technical staff. This person should be elected by 
the institution's technical staff. At least one person should rep- 
resent the health department of the local government. This person 
should be selected by the local health department. The remainder of 
the non-af filiated members should be persons who may be reasonably 
expected to represent the interests of the general public. DHEW's 
proposed regulations for the governing bodies of Health Systems Agencies 
also calls for persons who may be reasonably expected to represent the 
interests of the general public. (43 Fed . Reg . 22858) 
IV-A-2-c. The failings of Institutional Review Boards, mandated 
by DHEW's regulations to protect human subjects of biomedical and 
behavioral research, and of the Harvard Medical School committee 
responsible for overseeing recombinant DNA research, indicates that 
specific NIH requirements for monitoring of ongoing experiments is 
essential. In the case of the Harvard committee ( supra note 2) , it 
is apparent that throughout the committee's long deliberations over 
the containment capabilities of Dr. Thomas' laboratory, no member of 
[A-347] 
