4 
NIH has also reviewed actions by the institutional biohazard 
committees to ensure that the research protocols comply with the require- 
ments of the NIH Guidelines. In the report accompanying H.R. 11192, the 
general administrative structure of the Guidelines is endorsed for 
purposes of regulation under the Act. Indeed, the Commerce Committee 
report encourages the Secretary to place most of the authority for local 
administration of the Act in the institutional biohazard committees. 
We are considering, in the proposed revisions of the Guidelines, 
further responsibilities for the biohazard committees. In our view, it 
is essential that the responsibility for primary oversight lie with 
these committees rather than at the Federal level. These local institu- 
tional responsibilities must be increased in view of the impossibility 
of a sufficient Federal police force to enforce standards externally. A 
corollary, however, is the need for a common set of Federal standards. 
In its March 1977 report, the Interagency Committee on Recombinant DNA 
Research recommended preemption to ensure a single set of national 
standards. As the Interagency Committee pointed out, the potential 
hazards, if ever posed, would conceivably extend beyond the local to the 
national and international levels. 
It is for this reason that we strongly favor preemption. It is the 
Administration's view that a standard of reasonableness, as determined 
by the Secretary, rather than necessity as in H.R. 11192, should apply 
when state or local governments petition to have their requirements 
govern. I would like to point out, Mr. Chairman, that the NIH Guide- 
lines provide for strict standards to govern this research, 
[Appendix B — 180] 
