30 
DR. FREDRICKSON: Yes, Dr. Gustafson, the Guidelines are intended to 
be standards for performance. The legislative proposals that have been 
discussed in the Congress this year represent attempts to embody those 
standards in legislation to provide what eventually would be regulations 
and enforcement through the regulatory process. We are currently in a 
self-policing, self-governing, non-legislative mode in regard to these 
Guidelines . 
DR. GUSTAFSON: Could I ask, then, whether your judgment is that 
that whole procedure is inadequate? Is there sufficient information for 
you to believe that? 
MR. DACH: I would agree that legislation is needed to further strength- 
en the teeth of these Guidelines. Yes, I do feel that we cannot at present 
trust the self-policing mechanism that we are said to rely on. The evidence 
that was presented in the University of California at San Francisco case, 
where at the public hearings one of the members, I think, of that biohazards 
committee mentioned that they had not revealed to the public the details 
of what they had done for fear of further inflaming the public on this 
issue--I think that that type of attitude--we haven't seen it in many more 
places--but I have a feeling it is there-- We just cannot trust people to 
take care of this problem themselves. That has been shown to us time and 
time again in other areas where there is a conflict of interest between the 
desires of the individual using a certain technique or a certain process, 
and public safety. 
Also, I would disagree that the intention of the Guidelines should 
be left solely to suggested rules of procedure. It seems to me that they 
were drafted with the intent of making sure that people followed those 
intended rules. There is mention of enforcement proceedings by NIH, the 
taking away of grant money if infractions are— 
DR. FREDRICKSON: Mr. Dach, excuse me, I think maybe you are get- 
ting over into roles and responsibilities, and I would like to reserve our 
discussion on that. 
MR. DACH: I was just trying to answer the question, but I will stop 
if he is satisfied. 
DR. FREDRICKSON: We have other public witnesses to hear on this 
subject, but we are on the matter primarily of definitions. I want to 
ask Mr. Dach one question, however, in regard to that. 
You referred to definitions of what would be covered by the Guide- 
lines as they appear now in Senate bill S — 1 2 1 7 , I guess, and HR-7897. I 
think, just for the matter of the record, did you mean to imply that those 
definitions did not considerably narrow the scope of what experiments would 
be covered under the present Guidelines? 
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