DNA/14 
In light of this experience, EDF suggests that, at the minimum, 
NIH require that an IBC inspect all laboratories carrying on recomb- 
inant DNA activities at least twice a year. This inspection should 
include review of physical containment equipment, the training of any 
new personnel hired, and laboratory notes to insure that no protocol 
changes were made that were unreported to the IBC. 
Copies of these inspection reports should be available both 
through NIH and the IBC. 
IV-A-2-f and IV-C-3. EDF maintains that all IBC meetings should 
be announced and be open to the public. All MUA's and project regis- 
trations should be publicly available. Public availability of these 
documents is crucial if the public is to oversee the performance of 
NIH and the IBCs. Without the information contained in these forms 
and presented at the IBC meetings, local community groups, individuals, 
local government agencies, etc., will be unable to determine if proper 
containment requirements are being followed for recombinant DNA ex- 
periments . 
The DD-NIH states (43 Fed . Reg . 33065) , "I do urge that local 
committees, when possible, have open meetings and suggest that all 
meetings be announced." However, this suggestion is not contained in 
PRG-NIH . Moreover, EDF disagrees with the DD-NIH statement (43 Fed . 
Reg . 33065) that IBC meetings cannot be open because of the possible 
discussion of proprietary and patentable information. This statement 
is based on an incorrect reading of applicable statutes and case law. 
EDF's reading of applicable statutes (5 U.S.C. .§552 and 18 U.S.C. 
§1905) indicates that the information in IBC meetings, MUAs and pro- 
ject registrations, concerning the work of non-commercial scientists, 
must be released to the public by NIH. 
[A-349] 
