Dr. Fredrickson 
Page Three 
to whom the task is entrusted are affiliated with the recipient 
institution. Provisions prohibiting participation by those 
with a "direct financial interest" cannot obscure the fact that 
the entire institution may stand to benefit, either financially 
or in terms of reputation, from the research under review. The 
interests of the institution, with which its staff can be expected 
to identify and to which they are accountable, cannot by any 
stretch of the imagination be equated with the interests of the 
public. Moreover, few people — even people with scientific 
training — are so far beyond human frailty that they can be 
expected to serve as objective and rigorous reviewers oblivious 
to the personal interests of their co-workers and friends, and 
to the institutional interest of the laboratory with which they 
are associated. These considerations point forcefully to the 
conclusion that even the scientists on the IBC should be appointed 
by some authority outside the recipient institution. 
Secondly, allocation of one vote to a non-ins titutional 
representative may be a symbolic nicety but can hardly be expected 
to provide the IBC with balance and objectivity. Such a half- 
hearted nod to the principle of public participation is nothing 
more than an empty gesture -- a gesture which ignores both the 
broad diversity of community views entitled to representation and 
the political reality that a lone outsider will have little 
influence and less power and may be quickly cowed into comformity 
and quietude. Moreover, since there is no limit on the number of 
IBC members, even the minimal impact of the non-institutional 
member on a five-member committee will be further diluted where 
the size of the IBC is increased. 
Furthermore, even the non-institutional member is to be 
appointed by the institution. The friends and acquaintances 
of the selectors are unlikely to constitute a broad cross-section 
of the communities. More fundamentally, it will be the rare 
institution which will appoint someone expected to pose a serious 
challenge to institutional policies or perspectives. Thus the 
present guidelines do not require a single public representative. 
They require only that one of the institution's representatives 
be someone not directly affiliated with the institution. Meaning- 
ful representation requires that representatives be chosen by 
and accountable to the constituency they represent. Serious 
consideration should be given to prohibiting the institution 
from appointing more than a single representative to the IBC. 
We strongly urge the adoption of the following changes in 
the proposed guidelines: 
(1) The IBC should have a minimum of seven members. Any 
smaller number is simply insufficient to permit adequate represen- 
tation of the diverse elements entitled to a voice in decisions 
regarding DNA research. The requirement for public representation 
[A— 378] 
