Industrial 
Union 
Department 
AFLiCIO 
81516th Street N.W. 
Washington, D.C. 20006 
202/393-5581 
May 23, 1980 
! 
1 
i 
Howard D. Samuel, President 
Elmer Chatak, Secretary-Treasure 
Director 
Office of Recombinant DNA Activities 
Building 31, Room 4A52 
National Institutes of Health 
Bethesda, Maryland 20205 
gir . RE: FR, April 30, RAC 
We object to proposal 18, which, would amend the Guidelines 
for recombinant DNA research to permit industrial members on the 
RAC. RAC has exceeded its authority by offering review and approval 
of industrial pilot plant and production processes. Any attempt to 
add industrial expertise to the committee, beyond that of industrial 
consultants who may already be members, is to convert the committee 
to a self-appointed consensus standards organization. Such a con- 
version is not advisable and, if it were to occur, it could be in 
violation of the current OMB circular on such bodies. 
The function of the RAC should continue to review research. 
Regulation of industrial production is the function of regulatory 
agencies. By this digression from the mandated functions of NIH , 
the nation's health research program is once again diluted by act- 
ivities not within NIH competency . 
Respectfully Submitted, 
Sheldon W. Samuels, Director 
Health, Safety and Environment 
I 
| 
SWS : pcs 
opeiu#2af 1-cio 
cc: Dr. Chamot 
Dr. Frederickson , Director, NIH 
Dr. Bingham, Assistant Secretary for OSHA 
Dr. Robbins, Director, NIOSH 
Vice Presidents 
Shelley Appleton • Kenneth Blaylock • Peter Bommarlto • Dominick D’Ambrosio • David J. Fitzmaurice • Wayne E. Glenn • Alvin L. Heaps 
Keith Johnson • William Lucy • Dan V. Maroney, Jr. • Frank Martino • Lloyd McBride • Charles H. Pillard • George Poulin • S. Frank Raftery 
Albert Shanker • Jacob Sheinkman • Carl W. Studenroth • J. C. Turner • Shannon Wall • Martin J. Ward • Glenn E. Watts • William W. Wynn 
[ 290 ] 
