U.S. Department Of Labor Assistant Secretary (or 
Occupational Safety and Health 
Washington, D.C. 20210 
SEP 2.4 1980 
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Dr. Donald Fredrickson 
Director 
National Institutes of Health 
5600 Fishers Lane 
Bethesda, Maryland 20014 
! . . 
Dear Dr. Fredrickson: 
As you know, both the NIH Recombination DNA Advisory Committee (RAC) 
and 0SHA, among others, have been concerned with how the recombinant 
DNA industry should be monitored in an attempt to protect workers 
from any existing or potential hazards which may be peculiar to this 
type of activity. 0SHA has been actively reviewing the ways in 
which we can fulfill our mandate in this regard. 
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In recognition of our need to develop a regulatory policy concerning 
recombinant DNA, representatives of 0SHA and NI0SH have been attend- 
ing the RAC meetings and participating in the meetings of the Inter- 
agency Advisory Committee on Recombinant DNA Research and of its 
Industrial Practices Subcommittee. In addition, NIOSH has under- 
taken a study of the industry and its potential hazards, as decribed 
in the attached memorandum, which will provide a basis upon which 
OSHA regulatory decisions in this area can be developed. We esti- 
mate that for completion of the NIOSH study and for implementation 
of OSHA's subsequent decisions, a period of approximately two years 
will be required. 
I regret that the RAC wishes to terminate its reviews of engineer- 
ing plans for proposed private-sector DNA operations. Because this 
would remove one of the existing procedures for promotion of biolo- 
gical safety in these operations, I would like to describe to you 
how OSHA proposes to deal with recombinant DNA workplaces during 
the interim period, until OSHA regulatory policy for this industry 
is developed. 
Until formal regulatory decisions are made, OSHA will regulate 
recombinant DNA operations under its current authority, standards, 
and guidelines. Thus, OSHA will respond to complaints from workers, 
unions, or others about recombinant DNA hazards by reviewing the 
complaints and conducting inspections as warranted. In addition, 
inspections can also be initiated by OSHA without receipt of a 
specific complaint if the workplace selection is made in conformity 
with OSHA's current guidelines on general schedule inspections. If 
an inspection of a recombinant DNA facility is undertaken, OSHA 
compliance officers will, consistent with OSHA established practice. 
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