established procedures. Monitoring reports should be filed regularly 
with the NIH. Provisions should be made to pay local monitors. The 
NIH could in turn establish postions to provide for periodic monitoring 
of labs by its own staff. 
The feasability of having the NIH establish fining provisions for 
those who violate the guidelines should be explored. This would bring 
flexability to enforcement of the guidelines, as the amount of the fine 
would be proportional to the nature of the violation. Fining provisions 
would have the additional advantage of creating an obvious incentive to 
uphold the Guidelines. 
Role of the Advisory Committee 
The lack of adequate diversity in composition which plagues the 
Institutional Biohazards Committee can also be found in the Advisory 
Committee. With all due respect to its members, the Committee has an 
artificially narrow approach to its task and a lack of accountability 
to the public in the crucial stages of decisionmaking. Dr. Suzuki 1 s 
testimony outlines many areas of concern which have not been addressed 
by this committee, including the issue of human genetic engineering. 
If the Advisory Committee is to become more responsive to social, 
ethicaland environmental concerns it must expand or divide. That is, 
either the present technically oriented committee should be changed 
to include more experts at evaluating the impacts of the recombinant 
technology, workers and members of the public, or a complementary 
committee should be formed to address these concerns. While technical 
expertise is indeed an essential component of a policy-making mechanism, 
it should not exist to the exclusion of comprehensive attention to 
other aspects of the issue. 
The NIH should actively pursue a process for decisionmaking which 
does not spoon-feed to the public but is instead nourished by the public' 
input. Two ways to achieve this include improving the accessability 
of the committee and changing the selection process of its members. 
Perhaps the committee could follow the model of the National Commission 
for the Protection of Human Subjects and meet at various locations 
throughout the country. This would provide opportunity for local-level 
input. The committee could also have meetings with paid invited public 
witnesses on a regular basis. Minutes of these meetings (and all data 
used in the committee's deliberations) should be published anu cir- 
culated. The selection of members for the Advisory Committee should 
be done with contributions ( e. g. , lists of names of potential members) 
from all of the various interests involved in this issue. 
By developing procedures that open up the decisionmaking process 
for recombinant DNA research policy, the ultimate policy set crth 
becomes more justifiable. In addition, future essays in developing 
science policy will benefit from this process. 
[Appendix A — 192] 
