1913 I Street, N.W. 
Washington, D. C. 20006 
Telephone: Code 202, 833-9680 
J 
22 September 1980 
Dr. Donald S. Fredrickson, Director 
National Institutes of Health 
9000 Rockville Pike 
Bethesda, Maryland 20205 
Dear Dr. Fredrickson: 
The Committee on Genetic, Molecular and Systematic Microbiology of the Board 
of Public and Scientific Affairs of the American Society for Microbiology 
would like to comment on several issues for consideration at the Recombinant 
DNA Advisory Committee Meeting on September 25 and 26, 1980. 
1. Item 7. We agree with the RAC proposal past in June 1980, to exclude 
regulatory functions dealing with industrial scale-up. We believe that the 
current mission of the RAC is appropriate and that its present constitution, 
representing scientific and public interests, is not well suited for a regu- 
latory role. Other bodies of the federal government already have the mandate 
to carry out regulatory functions and should acquire necessary resources and 
expertise. 
2. Item 8. At present, we do not believe that there are good reasons for 
changing the registration requirements. Although present procedures demand 
some extra paperwork, they permit centralized keeping of files which could 
be of significant use in reviewing the extent of work on recombinant DNA and 
its possible hazards. Somebody should know what is going on. 
3. Item 11. We have long held the view that the RAC membership should include 
persons versed in scientific aspects of industrial microbiology. As with the 
rest of the Committee, they should be selected for the excellence of their 
qualifications. Such persons would complement the present technical expertise 
of RAC by providing knowledge in areas of fermentation technology and large- 
scale industrial applications. This expertise differs from that of safety engin- 
eers and is concerned with basic biological problems of large-scale technology. 
The Committee on Genetic, Molecular and Systematic Microbiology made recommendations 
for industrial representation on RAC in a letter to you dated 24 April 1980. 
Sincerely yours. Aft 
Moselio Schaechter, Ph.D. 
Chairman, Committee on Genetic, 
Molecular and Systematic Microbiology 
C.D. Cox, Ph.D. 
Chairman, Board of Public and 
Scientific Affairs 
BOARD OF PUBLIC AND SCIENTIFIC AFFAIRS 
AMERICAN SOCIETY FOR MICROBIOLOGY 
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