73 
DR. JACOBS: We are developing a procedure which is analogous, or a 
policy analogous to the one for the research on or involving human subjects, 
where whether or not NIH funds the research it must be done under the scru- 
tiny of an Institutional Human Research Committee, and approved by that 
committee. 
MRS. PETERSON: That might be a committee — 
DR. JACOBS: Excuse me, one second. If there are any infractions, NIH 
would not only withhold funds if it were the granting agency, but even if 
the work were done under grants from some private organization NIH would 
exercise the sanction against the institution to make it ineligible for 
grants for other purposes. We would do the same thing here for the DNA 
recombinant. So in that way we have some strength in enforcing the guide- 
lines, to the extent that we can be apprised of what is going on in those 
laboratories . 
Now, there is one important point about all of this work, and that is 
that the only reason for doing the work is to make contributions to knowl- 
edge, and you make the contributions to knowledge by eventually publishing 
your results, and if, in the publication of the results you reveal that you 
have been doing things improperly, say, like working with a botulinus toxin 
gene when that is proscribed, you are subject to the criticism of your peers, 
and it doesn't do you any good to advertise yourself as a very irresponsible 
individual. 
So there is a peer pressure, also, to see that the work is done within 
the constraints which the scientific community is developing. 
DR. FREDRICKSON: Technically, then, Mrs. Peterson, we are discussing 
guidelines here to influence research that is supported by the NIH or in 
institutions where other support is given to that institution from NIH. 
Actually, though, I think it not an exaggeration to say that we are setting 
a precedent here in terms of setting guidelines that are very likely to be 
adopted by many other funding agencies within this country, and probably 
around the world. The nature of the guidelines, their legal standing, I 
think is again something that I think we ought to take up in a little more 
detail. 
DR. BERG: May I add one point to that? 
DR. FREDRICKSON: Yes, Dr. Berg. 
DR. BERG: I think there are institutional responsibilities in fact, 
where most of the laboratories where this work will be done. By that I mean 
universities, research centers, and they in fact are looking to these guide- 
lines to develop inhouse review which will be independent of the granting 
process. 
[214] 
