Page 2 
Januazy 28 , 1982 
This suggests that the level of all remaining \jnoertcdnty is still substantial, 
i.e. that the oonstriction crurve reflects welocme change primarily in only one 
area of urraertainty. No concerted medTanisn for assessing the other areas has 
been created. Ihere is ground for concern that adcpticai of the RAC proposed 
will be interpreted as a signal that all risk hcis been eval\]ated and brou^t 
to manageable levels. Cn the other hand, it is clear that the NIH, already 
stressed by an unusual and probably inappn^riate regulatory burden, is not 
the ideal site for decision about the broader moerta inties. Moreover, the 
situation itay indeed have reached the point vhere a continued regulatory 
operation for primarily NIH purposes has beocme superfluous and unnecessarily 
burdensdni^ 
These considerations sxaggest an intermediate position between the tvo pending 
proposals. RAC has played a constructive role and is the single federal site 
vhere ooncerted public ddaate goes on about RENA policy. Vfere RAC to ooi?>le 
adoption of the Gotteanan prc^xjsal with a provisional endorsement of its cwn 
proposal as an Objective to be achieved in a defined period, say three years, 
extrapolation of the ooSiSstriction curve of NIH activity would be clearly 
delineated. Mean»hile, RAC might then also reocmnend that the intervening 
time be used to make best possible estimates of at least the first three areas 
of uncertainty en u nerated above. In so doing NIH oould enlist the support 
of other appropriate federal (the inter-agency ocranittee) and non-federad 
agencies, with special attention bo possible need for a continuing mechanism 
for further assessment and acticm. 
Such. reoGRinendations would aisure that NIH does not abruptly and prematurely 
drop a responsibility it has honorably ^mildered. Moreover, a mistaJcen con- 
clusion that all uncertainty has been dissolved would be avoided and opportunity 
would be afforded to consider sound policy for many spin-off effects that are 
likely to generate cjontrover^ for sene time to ocroe. 
Very best regaunds. 
Sincerely yours. 
Clifford Grobstein 
GG:aw 
[ 708 ] 
