68 
MR. DACH : It pays to go at the end, because then I don't have to say 
the things I thought to say. I wish I had recognized that in the beginning, 
and I wouldn't have taken the time to write them up. 
Anyway, I wanted to really reiterate what Jon said about the importarce 
of training and the importance of specifying the good microbial technique 
that I guess was formerly contained in Appendix D. The physical containment 
requirements are certainly basic to the Guidelines' goal of safeguarding 
the public health, and laboratory practices, as mentioned in the Guidelines, 
are a primary defense against release into the environment of these poten- 
tially dangerous organisms. 
Again, however, the description of these required practices is often 
too vague to really be a guide, and hard to monitor and difficult to enforce. 
It is the story I mentioned before. I am quoting from the Guidelines where 
it says, "The first principle of containment is strict adherence to good 
microbiological practices. All personnel must be required to undergo ade- 
quate instruction." Clearly we should expect a different definition of "ad- 
equate instruction." The Guidelines should specify this in detail. 
The Occupational Safety and Health Administration runs across problems 
like this continually when it deals with worker regulations on hazardous 
chemicals, and it has developed ways to come up with very distinct and de- 
tailed training manuals, training courses that have to be certified, getting 
the information on how to use these chemicals to the worker. 
Another example in that same section is where it says that the emergency 
plans must be--should be available. If an emergency does occur with an ex- 
tremely dangerous organism, it would seem that the plan should probably be 
certified by at least the local biohazards committee. Emergency plans can 
range from a little to a lot, and we should be sure that they are adequate 
to deal with an emergency. 
Finally, another ambiguity, or at least vagueness, is where it says at 
the end that serological monitoring, where appropriate, should be performed. 
Maybe that is clear to the people involved in this research, but it wasn't 
clear to me whether that was a decision that should be left up to the insti- 
tution or whether there is a chance for that to be specified in more detail 
in the Guidelines themselves. 
I would also like to reiterate the point that as good as the special 
laboratory facilities or containment facilities may be, if people do not 
follow the laboratory practices they are going to take the dangerous orga- 
nisms out with them into the environment. Even the best physical containment 
labs have been shown, time and time again, to result in those kinds of in- 
fections. There was a recent article in the New England Journal of Medicine 
about cases of Rocky Mountain spotted fever, and I am sure there are other 
examples . 
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