5 
escape from their specially contained environment in the laboratory. 
Presently, the Recombinant Advisory Committee must review all 
$ 
applications for new host-vector systems and recommend for certification 
those that meet the relevant criteria. 
Because of the technical complexity of these certification 
decisions, the Recombinant Advisory Committee must frequently defer 
its recommendations for certification for several meetings in order 
to evaluate further scientific evidence. It was this latter circumstance 
that posed difficulties for the researchers at the University of 
California in San Francisco, who cloned genes in a host-vector system 
not approved at that time and therefore had to destroy their work 
and begin again once approval was granted. We have devised 
better lines of communication to ensure that investigators and 
institutions are kept fully aware of the status of their requests 
for certification. 
There is no question but that experiments have been postponed 
and some scientific work delayed by the presence of the Guidelines and 
their implementation. At the same time, having embarked upon this 
course of self-restriction, NIH believes it must guarantee the 
integrity of the administrative safeguards and assure that due 
process is observed in implementation and revision of the Guidelines. 
Mr. Chairman, I would like to insert for the record relevant 
documents on the implementation of the NIH Guidelines. 
[ 382 ] 
