69 
The difficulties in the prospects of maintaining good laboratory prac- 
tices are really maximized by the near impossibility of making sure that 
those practices are actually followed, especially among people who might not 
really agree that this research poses a dangerous risk to the health and the 
environment. It is the kind of thing that requires care, and unless you are 
convinced that that care is necessary, you are unlikely to take the time. 
Because we are undoubtedly going to have to deal with people in that cate- 
gory, I think it is important to insure that good monitoring and continual 
monitoring occurs of people doing this kind of technology. That kind of 
thing doesn't show up in the certification. Really, in the MUA there is no 
certification that that kind of practice will continue. 
The Guidelines do call for the biological safety officer to begin moni- 
toring this kind of work, and I think that is a good thing. There have to be 
periodic inspections and monitoring — routine, unannounced, periodic inspec- 
tions. Also, though, there should be inspections by non-facility personnel. 
I think the conflict of interest between people working for a university with 
the potential for discovering an infraction that might result in termination 
of funds is too great to have confidence in the fact that they will always 
report what is going on. We need to have non-inst itut ional members on the 
biohazards committee. We need, as Jon said, to have representatives of the 
workers. That again is somewhat in the roles and responsibilities, and we 
will discuss that more tomorrow. 
Similarly, the penalties for discovery of possible infraction have to 
be stiff to be an incentive for compliance, but at the same time they have 
to be invokable. I think it is the first and a basic rule of a regulatory 
agency that if you come up with a penalty that is outrageous, it is rare 
that it is ever going to be enforced or used. The only penalty available 
now, it seems, is removal of research funds. It is unlikely that that is 
going to be used for someone who doesn't wash their hands, or smokes in the 
laboratory. But we need some sort of incentive for those people to get at 
the possible violations of these Guidelines. 
I have a few brief comments that I would like explained to me a bit 
more; the problem of putting the universal biohazards symbol on refriger- 
ators, I wonder if this is really enough, preventing either accidental or 
deliberate release into the environment of these organisms. Perhaps things 
like that ought to be locked. 
I agree with the problem of the autoclaves in the P3 facilities. The 
Guidelines only say that you have to keep a durable plastic container. That 
might be a Rubbermaid dishpan. Maybe we need some words on that. 
And finally, in P3, one thing that was confusing to me was that it 
allows dispersal of exhaust air into the environment, but it cautions you 
not to allow it to go back into the building from which it emerged. Maybe 
this is clear, but it is not clear to me. If it is too much of a hazard 
for the rest of the building, why isn't it enough of a hazard for the people 
walking on the street? 
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