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1 fulfilling that function. 
2 Recommendations. EPA, OSHA, FDA and CEQ should 
3 have full voting membership on the RAC. This is essential 
4 now that the NIH is accepting voluntary compliance by 
5 industry. In order to protect proprietary information, 
6 the RAC will have to hold meetings not open to the public. 
7 We need to have some assurance that our concerns will be 
8 represented. 
9 Perhaps more importantly, the RAC could use the 
10 advice of experienced regulators, particularly as they 
11 begin to deal with industry. 
12 The Interagency Committee is not adequate 
13 participation and input for these agencies. It has not 
14 met once this year. The advice of EPA and OSHA in parti- 
15 cular will always be appropriate, as referred to on page 
16 33051 , they should be fully involved in the decision-making. 
17 The majority of open spaces on the RAC should 
18 be filled with individuals nominated directly by the public. 
ig Until we have members who share our perspective, and whose 
} 
20 judgment we trust, the decisions of the RAC will always be 
21 suspect. This trust is in the long-term interest of the 
22 NIH as well as ourselves. 
23 Penalties. HEW must find some mechanism by which 
24 penalties can be assessed appropriate to the infraction, 
25 and then use them as required. 
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