To: Hon. Ray Thornton 
January 19, 1982 
Page 2 
Even though the IBCs and RAC have been largely controlled by r-DNA 
researchers and associated scientists and administrators, there are many 
indications that their functioning has been salutory in regard to assuring 
high quality research which is socially responsible. They also offer the 
public (which has supported so much of this work with its dollars, bears the 
risks and any hazards which result, and will share in the benefits which 
materialize) at least some measure of input into the decision-making process 
and increased information about the activities which are being conducted. 
These mechanisms should be improved, not abandoned nor atrophied, and member- 
ship rotation should be accomplished so as to insure that individuals with 
a demonstrated track record of public interest activity sit on the IBCs and 
the RAC (unfortunately, the reverse has been occurring). How else is public 
confidence to be maintained in these areas? Certainly, the blandishments of 
self-interested scientists who are increasingly jockeying in the commercial 
r-DNA arena will not serve to allay public concerns. 
The call for "voluntary compliance" has come to evidence a trade association 
mentality compatible neither with the public's rightful expectations nor the 
historical experience with self-regulation of conmercial activities (which 
DNA surely is at this time). The assumption behind Baltimore-Campbell that 
self-regulation will protect the common weal is unlikely to prove valid. 
The irony is, of course, that the overwhelming majority of r-DNA work is 
currently unregulated at the Federal level, after the successful campaigns 
by Drs. Rowe and Campbell, Singer, Adel berg, and others to greatly modify 
the 1978 Guidelines. The public in most communities requires greater regu- 
lation of its barbers that its r-DNA researchers, an absurdity I agree, but 
one not helped by the current proposals before the RAC. 
The claim that adherence to the Guidelines is costly and cumbersome is a 
familiar argument, always advanced by special interests desiring to elimi- 
nate public accountability. Unfortunately, there is no indication in the 
Federal Register supporting materials that the only two studies of IBC 
composition and performance ever conducted (see testimony of Pfund to HEW 
panel. Sept. 1978; presentation by RAC, 1981) are being considered in 
evaluating proposals to abolish the IBCs. The second of these studies, in 
particular, indicates that the committees have performed well in many respects, 
not significantly hindered research progress, etc. Unfortunately, the prom- 
ised NIH evaluation of IBCs has been postponed until after the Baltimore- 
Campbell proposal is decided; this is another example of an Alice-in- 
Wonderland logic which calls for "the verdict first, the evidence afterward." 
1675) 
