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I. FOREWORD 
In this section of the Draft EIS, the development of the "NIH 
Guidelines for Research Involving Recombinant DNA Molecules" was 
discussed. Some commentators considered the public role in that 
development inadequate [ 12, 26, 30]. The National Institutes of Health 
recognizes its responsibility to ensure opportunity for public review 
and participation. All meetings of the Recombinant Advisory Committee 
were advertised in the Federal Register and open to the public, and 
as previously noted, a public hearing on the proposed Guidelines was 
held at NIH in February 1976. The Guidelines were revised on the 
basis of that public response. They were then issued, on June 2 3, and 
were published in the Federal Register on July 7 to provide further 
opportunity for comment. Accompanying the NIH Guidelines was the 
"Decision of the NIH Director" addressing the issues that public 
commentators had raised at the February hearing and in subsequent 
correspondence. 
The publication of the Draft EIS in the Federal Register provided 
yet another means to obtain public participation. The Guidelines also 
provide for public review of the conduct of research in that they 
recommend broad representation on all institutional biohazards commit- 
tees that oversee the research. The NIH scientific committee responsible 
for developing and reviewing the Guidelines (Recombinant Advisory 
Committee) holds open meetings, and its actions, in turn, are reviewed 
and monitored by a public advisory group to the NIH Director. 
A number of commentators observed that the Guidelines were re- 
leased prior to completion of the environmental impact assessment. 
They asserted that this action was in technical violation of NEPA 
[12,20,26, 30]. As explained here (and in the Draft EIS), however, 
the NIH maintains that the public interest required immediate issuance 
of the Guidelines to protect the safety of persons conducting this work 
and of the general public. 
A number of commentators did not agree that the issuance of the 
Guidelines was a "major Federal action" as defined under NEPA 
[20,26], but suggested instead that the major Federal action was NIH's 
funding of research. In fact, none of the NIH individual grants or 
contracts involving recombinant DNA research supports such research 
per se. Rather, this research represents merely one among many 
techniques used under these grants and contracts for basic biomedical 
research aimed at ultimately improving the Nation's health. 
