2 
clean up of major contamination of work area or personnel should be a 
required part of the investigators ' s MUA, should bear the signitures of 
laboratory personnel and should be approved by the local biohazard com- 
mittee. 
The laboratory setting can, at times, be a very isolated one. A 
good example is the research group at this university doing polyacryl- 
amide gel electrophoresis and being unaware, as of six months ago, of 
the extreme toxicity of acrylamide. The point I want to make here is 
that information on real dangers may be so poorly circulated that even 
very careful people may suffer. Recombinant DNA work is only one kind 
of hazardous work, but no matter what the origin of the hazard, a "let 
the buyer beware" philosophy is unacceptable. One solution might be a 
newsletter (with references) for technical staff which would provide 
information to help them deal with the ever increasing barrage of chem- 
icals, organisms and particles. (i would be happy to provide more ideas 
on this subject at your request.) 
One last point I would like to raise is related to periodic inspec- 
tion of all facilities for compliance with the guidelines. The idea of 
inspections doesn't particularly appeal to me, but I believe that be- 
cause of the cohesive nature of laboratory groups, it is unlikely that 
violations will be reported by technical staff or graduate students. 
In my experience, regulations of the Occupational Safety and Health 
Act protecting workers' rights in such cases are generally unknown to 
staff people here. Thus I would favor inspections, certainly of P-3 
facilities at least, to monitor compliance. 
As a member of an institutional biohazard committee (iBC) attempt- 
ing to implement the NIH guidelines, the elimination, to the greatest 
extent possible, of vague language from the revised guidelines would be 
a great service. A specific example involves the two references to work 
with naked DNA where more specific information on inactivation proceedures 
as well as using the same terminology to describe the required containment 
(minimal vs. P-l) for such work would be very helpful. The problems and 
pitfalls of interpretation mean that throughout the country a variabil- 
ity in application of the guidelines is bound to exist. Perhaps like 
many other institutions, the University of Washington initially adopted 
the NIH guidelines as the minimum standards for recombinant work here. 
[Appendix A — 223] 
