-5- 
document mentions this issue. It indicates that two non-scientists 
are currently RAC members and that more public members may be added.) 
Our written comments will provide more details on this issue. 
Requirements similar to the ones I have outlined are contained in 
HEW's proposed regulations for the governing bodies of Health Systems 
Agencies (43 Fed . Reg . 22858) . 
EDF maintains that at least one-third of the RAC be composed of 
individuals who are not engaged in biomedical research and who can 
reasonably be expected to represent the interests of the general public. 
Such individuals would include representatives of labor, public interest 
groups and elected or appointed public health officials. A sub- 
committee composed of a majority of RAC members who represent the 
interests of the general public should be given authority to make 
recommendations to the Director of NIH concerning exceptions to pro- 
hibited experiments and exemptions from the guidelines. 
I will discuss our final two areas of concern, confidentiality 
i, 
and the membership and responsibilities of the Institutional Biosafety 
i 
Committees simultaneously. IBCs have primary responsibility for in- 
suring compliance with the guidelines. 
I do not heve time to describe the membership and responsibilities 
of IBCs as outlined in the proposed guidelines. I will therefore 
proceed immediately to a description of the changes EDF feels are 
necessary. 
One-third of the membership of each IBC should be composed of 
individuals who have not been affiliated with the institution for at 
least a year. prior to their service on the IBC. At least one of these 
individuals should be a non-doctoral person from a laboratory technical 
staff. This person should be elected by the institution's technical 
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