DNA/17 
a situation. Failure to require cessation of work under these circum- 
stances allows experiments not conforming to the regulations to con- 
tinue.. Cessation also provides strong incentive for quick correction 
of problem situations. A less satisfactory option would be to allow 
10 days for repairs. Work would be halted if repairs were not com- 
pleted by that time. The IBC should certify in writing that repairs 
have been made. 
IV-B-l-b. PRG-NIH does not clearly describe procedures for 
future revisions of the "Guidelines". EDF maintains that the "Guide- 
lines" should be revised by regulation, after public notice and comment. 
All proposed revisions should be published in the Federal Register , 
with a detailed preamble supporting the proposed changes. All rele- 
vant background information should be available to the public. A 
minimum 45 day public comment period should be provided. An informal 
public hearing should be held during the comment period. 
IV-B-l-c. (See section II-D of these comments.) EDF agrees that 
no new host-vector system should be used in recombinant DNA experiments 
until it has been certified, via publication in the Federal Register , 
by the Director of NIH. However, this procedure must be clarified 
since section II-D of PRG-NIH does not clearly indicate which office 
in NIH must certify new host-vector systems. EDF's comments on sec- 
tion II-D provide our views on the nature of appropriate notice and 
public comment in this area. 
IV-B-l-d. Section I-E of these comments contains EDF's views 
on the nature of appropriate public notice and comment for this area. 
EDF further maintains that a person applying for an exemption should 
be required to show that the activity in question does not present a 
significant risk to health or the environment. The mere fact that a 
[A-352] 
