5 
the ecosystem without actual experimentation (for example, 
Legionell a) is to deny the major body of public health 
experience . 
Absence of Appropriate Expertise and Representation 
- Though improvements have been made in recent 
appointments to the RAC, the data base for their 
del iterations , namely previous reports and di scussions , were 
developed with minimal input from those with experience in 
occupational or environmental health, or industrial 
regulation. For example, representation from organized 
labor , particularly those sectors liable to be employed in the 
industries mbs minimal. Representation from organizations 
such as the American Public Health Association, Society for 
Occupational and Environmental Health, Sierra Club, Friends 
of the Earth, and other constituencies who have developed 
substantial technical expertise was also minimal. 
- This is obvious in the absence throughout the RAC 
deliberations of reference to previous regulatory experience 
with pesticides , organics , heavy metals, carcinogens, or other 
health hazards associated with new technologies. The concrete 
experiences of attempts to predict risks before hand in other 
industries would suggest vastly greater caution than is 
called for in the Baltimore/ Campbell proposals. 
Conflict of Interest 
- The Baltimore/ Campbell proposal, if passed, will almost 
certainly be presented as a voluntary code for all rDNA 
activities, private and public, laboratory or industrial. 
Thus its actual character will be to weaken or eliminate the 
prospects for regulating emerging commercial activity .These 
porposals have certainly been looked on favorably by 
commercial Interests and that sector of the scientific 
community that stands to profit from rapid commercial 
exploitation . 
- If recent corporate prospectuses are correct, some 
members of RAC involved in the efforts to dismantle the 
guidelines have equity positions in corporations who stand to 
benefit from a relaxed regulatory climate. The Federal 
Register docunents make no mention of this conflict.lt was ray 
understanding that members of government committees are not 
permitted to have investments in corporations they are 
charged with regulating. 
In sunmary I recotranend that both the original and the 
modified Baltimore/ Campbell proposals be rejected. The 
existing Guidelines are administratively awkward and do need 
improvement. However, the character of the changes are the 
addition of health surveillance, systematic monitoring of 
unintentional releases o organisms, continuing risk 
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