Page 2 of Attachment I 
Donald Fredrickson , a. D . 
Page 2 
recommend that an expert panel under the direction of 
David P. Rail he convened to specifically address the 
hazards of recombinant DNA use particularly as they 
apply to potential occupational exposures. Such a panel 
would certainly benefit from the active participation by 
members from the HIS Recombinant DNA Advisory Committee 
but the panel should also include technical representa- 
tives from unions, management, public interest groups, 
and other concerned parties . OSHA would be happy to 
help in the selection of the expert panel and would 
participate as needed. 
OSHA would also support an active role by the National 
Institute for Occupational Safety and Health. A 
registry of all users of recombinant DNA material 
would be an important step in defining the scope and 
extent of use of recombinant DNA material and would 
facilitate continuing evaluation of any adverse health 
effects or toxicity. A survey of current users and 
industrial firms intending to use recombinant DNA and 
an evaluation of the experience with the current NIH 
guidelines could provide the basis for a joint NIQSH/ 
OSHA health hazard alert or a Current Intelligence 
Bulletin. 
OSHA could also review the NIH guidelines and publish 
them in an appropriate form as interim guidelines to 
industry. While these would net hold the force of 
regulations, they would indicaue our support for control 
in this area and would also provide information to 
employers indicating what we feel are appropriate pre- 
cautions and procedures of recombinant DNA use. 
Finally, the Environmental Protection Agency should be 
encouraged to explore enforcement of recombinant DNA 
use through its jurisdiction derived from the Toxic 
Substance Control Act. 
Initiation by OSHA of formalized standard setting is 
probably prematura at the currant time primarily because 
of limited understanding of the potential risks to 
[480] 
