AMERICAN FEDERATION OF LABOR AND CONGRESS OF INDUSTRIAL ORGANIZATIONS 
•XICUTIVi COUNCIL 
OlOKGI MtANY LANK KI^KLANO 
RRESiOCNT HCWIIIMMISIUK 
RAUL MU 
MATTHEW CU i NAY 
Frederick oneai 
CEO act haaot 
WIUIAM SIDEll 
C. 1. OCLLUM) 
EDWARD T. HANLEY 
WILLIAM H. McClENNAN 
oavio i. FirnuumcE 
alyin e yea n 
WILLIAM A WYNN 
JOHN H LYON) 
PETER 8QMMAR1T0 
JERRY WURF 
AL H. CHESSER 
MURRAY H. FINLEY 
CLEAN £ MATTS 
ANCELO FOSCO 
1 C TURNER 
AENNETH T rlayiock 
HARRY R POOLE 
FRIO 1. RROU 
A F. CROSPIRON 
THOMAS W, Cl EASON 
S. FRANK RAFTER! 
MARTIN J WARD 
ALSERT SHARKER 
SOL C. CHAIKIN 
CHARLES H PIILARO 
LLOYD McRRIDE 
EMMET ANDREWS 
MM w, MINPISINCER 
IOHN ) O OONNEU 
SIS SIXTEENTH STREET. N.W. 
WASHINGTON. D C. 2 QOOS 
(ZO» S 37 -SOOO 
Dr. Donald S. Fredrickson 
Director 
National Institutes of Health 
Bethesda, Md. 20205 
Dear Dr. Fredrickson: 
August 23, 1979 
A proposed supplement to the NIH Guidelines for Recombinant 
DNA Research appeared in the August 3, 1979, Federal Regis ter . 
These additions provide a mechanism for voluntary compliance with 
the Guidelines by corporations otherwise not covered by them. 
I would like to express most strongly our view that these 
new sections not be added to the Guidelines. The history of attempts 
to provide adequate health and safety protections to American workers 
is replete with tragic examples of employer callousness and employee 
suffering. Voluntarism is not sufficient. 
Currently, with commercial interest in this technology 
increasing rapidly, a major problem is lack of complete knowledge 
even of who is doing experiments with recombinant DNA techniques. Those 
with something to hide will not be revealed by any voluntary system. 
We firmly believe that regulatory authority over health and 
safety of workers must be the responsibility of the Occupational Safety 
and Health Administration. Promulgation of your inadequate and impotent 
Guideline additions can only hamper efforts to provide proper oversight 
by OSHA. 
Therefore, these Guideline sections should not be adopted. NIH 
has no business intruding upon the affairs of non-grantees or other 
government agencies. 
Sincerely, 
Director 
Department of Occupational 
Safety and Health 
GT/bw 
opeiu #2, afl-cio 
[ 311 ] 
