198 
DR. AHMED: Thirty-seven? But in terms of institutions, aren't they many 
of them happening in the same place, or are they all 37 different insti- 
tut ions ? 
DR. GARTLAND: I can't answer that right now. 
DR. AHMED: Okay. The question I have is why not P2 , for example? And 
it is very likely that any place that P2 work is going on, that eventually 
there will be a P3 facility being requested. Couldn't they sort of set up 
the mechanism now in order for the officer to become more familiar with his 
responsibilities, and be more knowledgeable about what is expected of him? 
DR. WALTERS: On this point, the Committee discussed the possibility 
of having biological safety officers at all facilities doing recombinant DNA 
research, even at the PI level, and decided to take an incremental approach, 
beginning with the requirement at P3 levels of containment. I suppose that 
that is a judgment by the Committee that the potential risks in P3 and P4 
research are greater than in P2 and PI. 
DR. AHMED: In one case you have the words "shall designate," but you 
could also provide for the possibility in which you don't have the "shall 
designate" for P2 facilities. They could initiate it like many places have 
already initiated such programs. Some directive from NIH may be useful in 
this regard. 
DR. FREDRICKSON: Dr. Ginsberg. 
DR. GINSBERG: I would only like to make a brief comment, and that is to 
commend the Committee on the language so that it is relatively flexible. One 
of the great problems that universities have today is the building up of 
layers of bureaucracy which are very hindering to research, and take up an 
awful lot of people's time to do nothing. I think that this helps to elimi- 
nate that as much as possible. 
DR. FREDRICKSON: Dr. DeRoos . 
DR. DE ROOS : I would just reinforce that comment that was just made 
here, that certainly they do need that flexibility, and it is very analogous 
to a radiation protection officer situation, where in smaller institutions an 
appointment can be made where maybe they only use radioisotopes in one labora- 
tory, and it is just impractical for that institution to appoint a full-time 
individual for that. 
DR. FREDRICKSON: Mr. Helms. 
MR. HELMS: Is it contemplated that the safety officer will have a did- 
actic function as well as a regulatory function, if you will. That is to say, 
will he be trained at all? And another part of that would be will he be 
trained, for example, any particular place? Will there be standards for being 
a safety officer? And then having acquired that knowledge, will he then be 
expected to teach it to others as well as to follow up and monitor? 
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