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out the fact that it simply will not work. NIH is simply not an enforcement 
agency. Enforcement requires experience; good intentions alone don't give 
us compliance. It is hard to be tough on people, and it is hard to devise 
appropriate procedures that are going to get people to comply with things. 
I understand that if NIH feels it should not do this job, or cannot do 
this job, then it should try to be passed on to somebody else. But meanwhile 
in the interim, they do have the responsibility to carry out this function, 
and they need to do it well, I encourage, though, in the meanwhile, that 
they do consult with other Federal agencies — OSHA, EPA — that have had much 
longer experience in enforcement, and begin to learn some of the bitter 
lessons that they have had to learn throughout their experience. 
It wasn't surprising to me today, what we heard — that the majority of 
people around the table felt that they didn't need excess bureaucracy around 
their universities. I think with 16 out of 22 people, as I quickly counted 
around the table, from universities, this is not really the fair forum to ask 
whether those kinds of things are necessary. 
In terms of people who are talking about the future, I think these Guide 
lines have to be seen as really the first step for the future discussion of 
problems of the use of this kind of technology, and if we can't figure out 
procedures for bringing the public in now, it is going to be hard later. Now 
is the time to start doing it. 
I would like to quickly go through more specifically what is in Section 
IV. In terms of the biohazard committee, I think we are all aware of the 
difficulty and the forces operating within academic institutions that really 
preempt effective enforcement. Professional etiquette is everywhere. We 
have learned this, time and time again, with physicians. Professional review 
of physicians is just totally a mockery. What graduate student do we know 
that is going to squeal on his or her thesis advisor two months before they 
are supposed to take their oral examinations? The pressures are just too 
strong . 
I think the makeup of the Committee must be changed, and it must be 
mandated. It shouldn't be recommended in the Guidelines; it should be re- 
quired. It should include at least a quarter public representatives, 
people accountable to the public, members of the local community, local 
elected officials. It should include technicians or students. It should 
include scientific expertise in physical and biological containment as well 
as in recombinant DNA. I realize some of these things are beginning to be 
met, but they should be required. 
The committee should be required to make periodic inspections of all 
facilities carrying on recombinant DNA research, at least every two months, 
and those inspection reports with procedures and with results should be 
forwarded to NIH for review by the central NIH office to make sure that 
those things are really happening. 
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