Response to U.S. AI Safety Institute’s Request for Comment on Managing Misuse Risk For Dual-Use Foundation Models

In this response to the U.S. AI Safety Institute’s (US AISI) request for comment on its draft guidelines for managing the misuse risk for dual-use foundation models, scholars from Stanford HAI, the Center for Research on Foundation Models (CRFM), and the Regulation, Evaluation, and Governance Lab (RegLab) urge the US AISI to strengthen its guidance on reproducible evaluations and third- party evaluations, as well as clarify guidance on post-deployment monitoring. They also encourage the institute to develop similar guidance for other actors in the foundation model supply chain and for non-misuse risks, while ensuring the continued open release of foundation models absent evidence of marginal risk.