MINUTES OF MEETING - June 5-6 
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OSHA, or its research partner, NIOSH, can use consultants as effec- 
tively as can NIH, and may have more staff competence. Such judg- 
ments can more appropriately be carried out by them, especially when 
they are related to a regulatory mission. 
From these considerations, I believe that the RAC should consider at 
least two options as it deliberates upon its procedures for handling 
industrial or private requests: 
1. to continue as it is until more experience dictates some new 
mode. Here keep in mind that an Industrial Practices Subcom- 
mittee of the IAC is actively studying the problem and will 
report to the IAC in the fall; 
2. to restrict its review and decisions to questions concerning 
biology and related issues of laboratory containment; and when 
containment for large-scale use is the issue, to judge only 
whether the specified P-LS level is appropriate (referring to 
the model designations in the April 11, 1980 Federal Register ) . 
The regulatory agencies will be fully apprised of such actions. 
They can make on-site evaluations if they deem them to be appro- 
priate to their regulatory mandate. 
With regard to the second option, I would note here that past actions 
of the RAC have included the insertion of a provision for visits by 
an NIH-designated person to industrial facilities that have been the 
subject of a RAC decision. If such visits are for purposes of corre- 
lating scientific information relevant to the duties of the RAC, they 
would seem to me to be still appropriate. Inspections for regulatory 
purposes shall be carried out by OSHA/NIOSH or other regulatory 
agencies having relevant authority. 
Finally, let me emphasize that it would not be appropriate for the 
RAC to decide, in exasperation, that it would like to avoid handling 
any proprietary data. From time-to-time, such material will have 
to be evaluated by the RAC in pursuit of its duties. I welcome the 
opportunity to participate in discussion of this matter to the extent 
that my presence will be useful." 
Following his remarks. Dr. Fredrickson opened the floor to discussion. 
Dr. Walters asked Dr. Fredrickson to amplify his remarks on the types of 
site visits which might be made to an industrial installation. 
Dr. Fredrickson replied that a visit to gather information regarding 
the implementation of RAC decisions and for the purpose of discerning 
how these decisions were applied to large-scale work was different from 
a visit by a regulatory agency. A visit frcm a regulatory agency would 
be made with the express purpose of evaluating compliance with the law 
and protection of employees. 
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