DNA/13 
the committee ascertained whether recombinant DNA experiments were 
being carried out. Here was a case where the committee was embarked 
on a detailed examination of a particular laboratory, subjecting it 
to far more scrutiny than usual for most laboratories, and yet the 
basic fact of whether research was being carried out was never de- 
termined. The experience of HEW with Institutional Review Boards (IRBs 
is also illustrative. Many IRBs approve projects without any stipu- 
lation for subsequent review after the project is initiated. More 
than two thirds of the IRBs did not appoint someone to observe the 
manner in which projects were conducted. Twenty percent of the IRBs 
felt that research could be conducted in a manner substantially dif-- 
ferent from the approved protocols without the IRB being aware of the 
changes. Finally, there was little improvement between pre- and post- 
review versions of informed consent forms, despite IRB requests for 
modifications, ( supra note 1) This illustrates a failure on the part 
of the IRB to follow through to insure implementation of its suggested 
modifications. A similar problem with oversight of ongoing experiments 
was revealed by Bradford Grey^. Grey concluded that many IRBs provided 
no continuing oversight of research projects. Moreover, several of 
the respondents in his study indicated that they would not conduct 
oversight because they thought it would inappropriately challenge a 
researcher's trustworthiness. (This reluctance to challenge the word 
Of one's colleagues is another justification for EDF's suggestion that 
IBC's include members who can be reasonably expected to represent the 
general public.) 
Human Subjects in Medical Research , John Wiley and Sons, New York, 
19 75. 
[A-3481 
