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Activities pertinent to the research agencies were reviewed by the 
full Committee in its initial meetings in the fall of 197 6. All research 
agencies adopted the NIH Guidelines as standards, including Agriculture, 
Defense, the Energy Resources Development Administration, the National 
Aeronautics and Space Administration, and the National Science Founda- 
tion. Of these, only Agriculture and NSF (as well as NIH) are currently 
supporting and conducting recombinant DNA research. Also, at the 
November 2 3 meeting, the Federal regulatory agencies reported on their 
regulatory functions. Following that review, a special Subcommittee was 
formed to analyze the relevant statutory authorities for the possible 
regulation of research involving recombinant DNA technology. All 
regulatory agencies were represented on the Subcommittee, assisted by 
attorneys from their offices of general counsel. These included the 
Office of Safety and Health Administration, Environmental Protection 
Agency, Food and Drug Administration, Center for Disease Control, 
and Department of Transportation, and Department of Agriculture. 
It was the conclusion of the Subcommittee that present law could 
permit some requirements to be imposed on much laboratory research 
involving recombinant DNA techniques, but that no single legal authority 
or combination of authorities currently existed that would clearly reach 
all research and other uses of recombinant DNA techniques and meet all 
stated requirements of the Committee. Although certain existing 
authority might be interpreted broadly to cover most of the research at 
issue, it was generally agreed that regulatory actions taken on the basis 
of any such interpretation would probably be subject to legal challenge. 
The full Committee adopted the report of its Subcommittee and 
agreed that new legislation was required. 
In considering the elements for legislation, the Committee reviewed 
Federal, State, and local activities bearing on the regulation of recom- 
binant DNA research. There was a concerted attempt to obtain 
information of relevant activities in developing Federal policy, including 
review of the recommendations by the New York State Attorney General's 
Environmental Health Bureau for State regulation and the Cambridge 
(Massachusetts) City Counsel's resolution on recombinant DNA research. 
Among Congressional proposals reviewed were S. 621, "The DNA 
Research Act of 1977, " introduced by Senator Dale Bumpers, and the 
companion measure introduced by Representative Richard L. Ottinger 
in the House (H. R. 3591). The Committee also noted the resolution 
introduced by Representative Ottinger on January 19, 1977 (H. Res. 131), 
requesting DHEW to regulate recombinant DNA research under Section 
361 of the Public Health Service Act. 
