13 
committees to biosafety committees to reflect the spirit of the guidelines 
more closely" is a reason without substance, and sounds like propaganda 
unworthy of this Department. 
Separating the Promotional and Regulatory Functions 
Government involvement in DNA research has been following the "AEC 
pathology" in failing to institutionally separate promotional agency activ- 
ities from regulatory ones. Unfortunately, the new Guidelines would not 
adequately address this syndrome. The intertwining of regulatory concerns 
with promotional activities is a further extension of the "old boy network" 
“G * 
suspicions I have referred to above, and reminds us of the widely-discredited 
situation which existed for many years in regard to nuclear power. Since 
the government has recognized what citizen groups have been saying for many 
years — in regard to atomic energy — and has established separate agencies to 
deal with these two different aspects of the situation, it is high time that 
similar procedures were begun regarding recombinant DNA. Promotion of a 
technology results in the vesting of professional, as well as of economic, 
interests in the application and exploitation of that technology. The expec- 
tations we have of regulators are far different from the types of commitments 
associated with promoters. In this regard, it is noteworthy that govern- 
mental decisions about recombinant DNA are being more explicitly made at 
the Departmental level rather than at the level of the NIH. But the AEC 
pathology should be recognized more directly and dealt with more satisfactorily. 
Hy concerns here are similar to those I expressed above in regard to 
the technological elite: how to assure that in a democracy decisions affecting 
members of the public are made democratically. As an example of the insufficiency 
of the Guideline revisions in this regard, I would refer to the Director's 
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