208 
We also do not take comfort from the fact that in the past, health 
effects of various industrial chemicals were not made known to the general 
public, nor for that matter to the workers who were using them until after 
undisputed evidence for serious harm had accumulated in the form of human 
illnesses and deaths — and in those cases, of course, the harmful materials 
were not capable of reproducing themselves. 
I mentioned that we worry about how closely voluntary guidelines will be 
followed. You are well aware, of course, of the violation of NIH Guidelines 
earlier this year at the University of California at San Francisco. This may 
well have been inadvertent, resulting from a misunderstanding about the 
procedures to be followed in certifying biological vectors, and no harm was 
done, but it was a violation nonetheless. The pressures on faculty and 
research students to be the first to publish new results, especially in 
exciting fields, are enormous; and it would be naive to assume that similar 
misunderstandings or lapses in judgment, or outright purposeful violation of 
voluntary guidelines, will not occur in the future. 
A long article reporting on the San Francisco incident appeared recent- 
ly in Science magazine, and in it David Martin, former chairman of the UCSF 
biosafety committee, is quoted as saying: "We can't run a policing service. 
What we do is try to raise the consciousness of the individuals involved to 
make them respect the Guidelines." Putting such enormous responsibility on 
the shoulders of what is basically a voluntary group of peers is asking too 
much, as is the expectation that all researchers of whatever age, of what- 
ever experience, of whatever social sense, of whatever commitment to the 
progress of science, will always follow the rules. 
I might mention at this point that industrial research, where the po- 
tential for large-scale operation is much greater than in a university, is not 
covered by the Guidelines at all. Industrial representatives claim that they 
follow the recommendations of the Guidelines, but there is really no way to 
check. They hide behind the veil of trade secrets. If an incident such as 
the one that occurred at San Francisco happened at an industrial lab, we 
probably would never hear about it, and yet I think they have a realistic 
notion of what is required. One of the participants at the NAS conference I 
mentioned earlier was Irving S. Johnson, vice president of research at Eli 
Lilly. He stated: "We thoroughly endorse the NIH Guidelines. I have made 
every effort, both within Lilly and within the Pharmaceutical Manufacturers 
Association, to lead the industry toward complete and voluntary compliance." 
But he goes on to say to the academic researchers in the audience: "It 
appears inevitable that there will be legislation in this area. I would like 
to suggest to you that this is something that we are going to be able to live 
with a lot more comfortably than you. In industry we are used to having 
people stand over our shoulder and suggest what we do, and I don't think that 
you in academia are, and I don't think you are going to like it." 
The question, of course, is not one of liking or not liking government 
regulation of research, but of protecting the public from harm. We are talk- 
ing about regulating the tools, not the ideas, and this is not new. No 
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