4 
(The publication of the proposed Guideline revisions, along with an accompanying 
environmental impact statement, and the holding of these public hearings is 
a welcome change from such previous patterns.) The existing Guidelines developed 
by the NIH are essentially the product of deliberations conducted by those who 
will be regulated by them; thus the situation has potential conflicts of interest 
built into it, and should be as suspect as the attempts by industry trade 
associations to forestall meaningful government regulation by the adoption of 
voluntary industry standards. The existing composition of the NIH Recombinant 
DNA Advisory Committee (RAC), and most of the IBCs, heavily (in some instances 
entirely) composed of researchers in this area, justifiably does not lead to 
public confidence in their decisions. Considering the fact that the primary 
issues raised by this research are not solely scientific nor technological but 
have major public policy components, the existing situation goes against the 
grain of the past decade's academic research and findings in the area of 
"science, technology, and public policy" as well as recent political ex- 
perience regarding the beneficial effects of citizen participation in many 
fields. The practices and experiences of the University of Washington's IBC 
are considerably more progressive- than what is envisioned under the proposed 
Guideline revisions; as a result, when I reviewed the revisions I frequently 
thought how more limited and reduced in effectiveness the operations of our 
IBC would be if we were to be following the model proposed there. 
I have organized my comments along four main themes: the social values 
raised by issues involving scientific research; the preferable roles in a 
democratic society for scientists and lay persons respectively to exercise 
in the regulation of research and its applications; the problems presented 
by having a single agency responsible for both the promotion and the regu- 
lation of an activity; and operational problems which I foresee if the 
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