6 
Following this proposal, there appear in the Federal Register of August 21, 
1980, proposed revised application procedures to implement this change. 
Dr. Gottesman said under this proposal the IBC would accept responsibility 
for assuring adherence to the physical containment guidelines. She said 
RAC would continue to evaluate the biology of the recombinant clones and 
the host-vector systems, but no longer deal with prior review of physical 
containment in individual applications. 
Dr. Krimsky said he had supported this proposal at the June 1980 RAC 
meeting. He had felt then that a government agency, such as the Occupa- 
tional Safety and Health Administration (OSHA), might more appropriately 
perform the function. He said that he had since learned that RAC's 
prior review activity is unique; there is no OSHA mandate for such prior 
review. He felt the RAC's prior review process serves an important func- 
tion. No other agency would perform this prior review should RAC extricate 
itself from the process. He preposed, as an alternative proposal, that 
there be established a subcommittee of the RAC made up of seme members 
of the RAC and some members of NIH staff with expertise in facilities 
and technologies, and that the subcommittee request representation from 
the Occupational Safety and Health Administration (OSHA), the National 
Institute for Occupational Safety and Health (NIOSH), the Center for 
Disease Control (CDC), and the Environmental Protection Agency (EPA). In 
this proposal, the subcommittee would review engineering and technology, 
and its review would be transmitted directly to the Director, NIH. 
Dr. Goldstein seconded Dr. Krimsky' s proposal. Dr. Gottesman did not 
accept the alternative proposal. Dr. Krimsky agreed to withdraw his motion 
with the understanding that it would be reconsidered later in the meeting. 
Ms. King stated that Dr. Gottesman 's proposal is an acceptable compromise, 
although she would prefer that the RAC withdraw from all review of indus- 
trial proposals. Dr. Mason noted that the RAC doesn't monitor even 
small-scale experiments. Dr. Gottesman said that the crux of the issue 
is whether evaluation of individual physical containment facilities by 
RAC is appropriate; she said it is not. Dr. Bems said that the RAC 
should consider only the biology of the systems. Dr. Goldstein supported 
Dr. Krimsky 's proposal; he said that there is not enough information 
available on local IBCs. 
Dr. Logan of OSHA felt RAC prior review of industrial applications serves 
an important function. He said that potential problems have been identi- 
fied by RAC, and he hoped the RAC would consider Dr. Krimsky' s proposal. 
It was suggested that Dr. Gottesman' s proposal could be divided and the 
last sentence of the motion voted on separately. Dr. Gottesman did not 
agree. Dr. Williams supported Dr. Gottesman 's position saying he' preferred 
to vote on the entire proposal. Ms. King agreed. 
[ 165 ] 
