4 
DNA. In response to her letter, he had suggested that these concerns be 
brought before the Committee. (See Attachment D for the exchange of correspon- 
dence.) Dr. Fredrickson then called on Dr. Bingham. 
Dr. Bingham stated that the OSHA Act of 1970 empowered the agency to 
enforce standards to make the workplace safe, but there are specific gaps 
in the law. It covers the private sector; public employees and universities 
are generally not covered. OSHA relies on NIOSH to provide recommendations 
and criteria for standards. Given OSHA's mandate, a number of its con- 
stituents have urged the agency to act on occupational safety and health 
concerns in regard to recombinant DNA research. She observed that every 
day more industries are developing a capacity for the technology and 
that it is essential to consider if and when standards should be promulgated. 
The technology introduces a vast new area of unknowns in occupational 
safety and health. OSHA, said Dr. Bingham, cannot wait for several years 
to promulgate standards, but on the other hand, more information would be 
required before action could be taken. NIOSH and OSHA look to Dr. Fredrickson 
and this Committee for guidance and advice. 
Dr. Anthony Robbins, Director, National Institute for Occupational 
Safety and Health, confirmed that his agency is also hearing from constituents 
who urge actions to provide recommendations for OSHA. There are problems 
of translation, however, in going from research guidelines to the regulatory 
mode. It is not clear that NIOSH will recommend standards. NIOSH is con- 
sidering industrial hygiene studies in these industries. There is a 
lack of data on what exposures might be in the industrial setting. 
Dr. Fredrickson said that in light of these concerns and the growing 
development of industrial application of recombinant DNA techniques, a 
subcommittee is needed to examine the issues. With the Committee's approval, 
a subcommittee was created with the following agencies represented: the Depart- 
ment of Agriculture, Department of Commerce, National Institute for Occupational 
Safety and Health of the Center for Disease Control, Food and Drug Administration, 
National Institutes of Health, Occupational Safety and Health Administration 
of the Department of Labor, Environmental Protection Agency, National Science 
Foundation, and the Office of Science and Technology Policy. The subcommittee 
is instructed to provide appropriate guidance to the full Committee on what 
steps, if any, need to be taken beyond the NIH Guidelines to cover occupational 
health in industrial production involving recombinant DNA technology. The 
subcommittee will be chaired by Dr. Gilbert Omenn of OSTP. The subcommittee 
should report at the next meeting of the full Committee on its progress, with 
a final report in the fall. (See Attachment E for a charge to the Subcommittee.) 
Dr. Fredrickson thanked the Committee for its cooperation in the develop- 
ment of Federal recombinant DNA research policies. He added that the next 
meeting would be devoted largely to the work of the subcommittee. In the 
absence of further business, the meeting was adjourned at noon. 
Respectfully submitted, 
Associate Director for 
Program Planning and Evaluation 
[ 326 ] 
