-3- 
allowed to renegotiate an increase in the overhead rate. A small percent 
increase should amply cover the cost for providing the monitoring and medical 
resources associated with that given project. 
12) The N.I.H. should request all Institutions which receive N.I.H. funds to 
develop a laboratory course for all incoming students.* 
13) I would recommend that the Recombinant DNA Advisory Committee review the issues 
very carefully. If on the basis of scientific judgement the Recombinant DNA 
Advisory Committee concludes that recombinant DNA research is sufficiently 
hazardous, (or potentially hazardous) such that the draft revisions are appro- 
priate, I would suggest that the N.I.H. set up a panel to consider the potential 
hazard aspects of research with microbiological agents in general, including 
etiologic agents. If recombinant DNA research is potentially hazardous, and 
therefore requires careful monitoring, then why not exhibit the same concern 
for Class I and Class II bacterial, viral or fungal agents? If coli K-12, 
is a potential pathogen, what then are P seudomonas , Serratia , Proteus , Enterobacter , 
Influenza viruses, etc.? 
14) The available data indicates that recombinant DNA research (like most micro- 
biological research performed in the laboratory) represents an occupational 
risk. This point is even supported by Professor Jonathan King (M.I.T.). In 
his testimony on 15 December 1977 he indicated that he was not concerned about 
epidemics with K-12, and that he felt that the laboratory worker was at risk. 
If this is true, and I believe that it is, then how do we protect laboratory 
workers from potentially hazardous situations? Containment facilities are designed 
to protect the environment, not the investigator. Investigators must rely on 
containment equipment, and on technique to protect themselves. It seems 
counterproductive (and very costly) to me to go through the expense of facility 
renovation, or the construction of new facilities, if this effort does not alter 
the occupational exposure/risk. The broader use of the safer strains (EK-2) 
can have an impact on occupational exposure (i.e., P-4, EK-1 — ► P-3, EK-2; 
P-3, EK-1 — ► P-2, EK-2). 
15) The N.I.H. should review the status of risk assessment experiment. In addition 
to the Martin-Rowe polyoma study, experiments which test the efficacy of contain- 
ment should be initiated. 
16) I would request the director of the N.I.H. request all Institutions that receive 
N.I.H. funding to require the Institutional Biohazard Committees review all 
recombinant DNA applications regardless of source of support (N.S.F., A.C.S., N.I.H., 
or Industry).* This would eliminate the possibility of investigators performing 
recombinant DNA research xtfithout the knowledge of the administrative structure of 
the Institution. 
I realize that the N.I.H, does not have the authority to require that Institutions 
initiate these actions. However, requests from the N.I.H. in these areas will 
encourage Institutions to consider these points. 
[Appendix A — 143] 
