- 2 - 
Furthermore, it would be much simpler to identify institutional recipients 
of NIH funds than to decide whether the guidelines should apply to an 
institution in which recombinant DNA activities, although not expressly 
supported by NIH, nonetheless benefit indirectly from NIH money used, for 
example, to purchase equipment or to pay the salaries of researchers or 
techni cians . 
2) Exceptions 
For the first time, the proposed guidelines would permit case-by-case 
exceptions to the existing prohibitions on certain categories of experiments, 
the release of recombinant DNA organisms into the environment, and the 
production of certain cultures in excess of ten liters. As Dr. Fredrickson 
correctly notes, "the widespread support for this authority reflects the 
realization that many important risk-assessment experiments may not be able 
to proceed otherwise." The House bill, H.R. 11192, endorses this principle 
as does the oversight report of the Senate Subcommittee on Science, Technology 
and Space. The grounds for such exceptions, however, go beyond the need for 
data to assess the hazards of recombinant DNA research. The "Decision" 
document states that exceptions may be made for experiments for which there 
are "compelling social or scientific reasons, for example, risk assessment 
experiments." The guidelines merely state that weight will be given in the 
decisionmaking "both to scientific and social benefits and to potential risks." 
[A-420] 
