commercial use of recombinant DNA techniques, even though the 
Secretary has the authority under section 361 of the Public 
Health Services Act (42 U.S.C. §264) to regulate all recombinant 
DNA activities. This decision not to regulate may well have 
more impact on the environment than issuance of the Guidelines 
because the environmental damage the Guidelines seek to prevent 
may well be caused by researchers at corporations, private- 
institutions or other federal agencies. Therefore the 
exclusion of non-NIH research from the Guidelines is a 
crucial part of the federal action which should be the subject 
of this impact statement. 
NIH has or can gather the information it needs to 
describe the extent and nature of the recombinant DNA activities 
not covered by the Guidelines. In his opinion which accompanied 
the release of the Guidelines, Dr. Donald Frederickson stated 
that he had met with representatives of other federal agencies 
and industry to discuss their recombinant DNA activities. Partly 
as a result of these meetings, the Pharmaceutical Manufacturers 
Association has formed a committee to review the possibility 
of voluntary adoption of the Guidelines by the drug industry. 
At least two private corporations are known to be investigating 
commercial uses of recombinant techniques. General Electric 
is trying to develop a bacteria which could consume crude 
petroleum and be used to clean up oil spills. Imperial Chemical 
Industries (ICI) is investigating the use of recombinant techniques 
9 
Appendix K — 135 
