Recombinant DNA Advisory Committee - 06/1-2/92 
sufficient, and whether questions related to safety, efficacy, and social and ethical 
context have been resolved. Whenever possible, criticisms of Consent Forms 
should include suggested revisions for the RAC to consider, provided as written 
alternatives. Reviews should also state whether the proposal is: (a) acceptable as 
written, (b) acceptable with specific revisions or after satisfactory responses to 
specific questions raised on review, or (c) unacceptable in its present form. 
During oral discussion of reviews at the RAC meeting, it should be possible to 
present most reviews orally within <; 5 minutes. 
Dr. Schaechter moved that the Strategies for Focusing Discussion at the RAC be approved 
as an addition to the Points to Consider. The motion was seconded by Dr. D. Miller. 
The motion to approve the addition of Strategies for Focusing Discussion at the RAC to 
the Points to Consider passed by a vote of 18 in favor, 0 opposed, and no abstentions. 
XIII. PROPOSED ADDITION TO SECTION IV-C-2 OF THE NIH GUIDELINES 
REGARDING CONFLICTS OF INTEREST: 
Review-Mr. Capron 
Dr. Murray called on Dr. Capron to present his review of the petition submitted by Mr. 
Jeremy Rifkin of the Foundation of Economic Trends, Washington, D.C. Mr. Capron 
stated that the petition addresses an important issue, the public perception of the lack of 
conflict of interest by the members of the RAC. Committee members are currently 
required to submit a financial disclosure document to NIH that is mandated by an 
Executive order dated September 25, 1986. This order carries out the requirements of 
Section 107 of the Ethics in Government Act of 1978. The issues raised by the petition 
are not particular to recombinant DNA but apply to all advisory bodies that are 
comprised of special government employees. The petition should be forwarded to Dr. 
Healy to be examined on a broader level. 
Review— Mr. Barton 
Mr. Barton said that the petition addresses an extremely significant issue. The NIH re- 
authorization bill before Congress addresses conflict of interest in the context of NIH 
grantees and not advisory committee members. The petition proposes revisions to the 
Federal Advisory Committee Act. Legislation is currently proceeding, proposed by 
Senator John Glenn, that would review the structure of Federal advisory committees. 
The proposed legislation addresses the concerns presented in Mr. Rifkin's petition. In 
addition, the Office of Government Ethics issued interim regulations in April regarding 
public disclosure by advisory committee members. Therefore, since these laws are 
currently subject to change, it may not be an appropriate time to present this petition. 
Recombinant DNA Research, Volume 15 
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