14 
discussion of the RAC (FR 33066) where he acknowledges having received many 
comments urging that the composition of the RAC be significantly broadened. 
(Much of the above discussion regarding the membership of the IBCs is rele- 
vant here and in the following observations.) His statement that more 
public representation on the RAC might be desirable, "including perhaps a 
'dissenter' from current NIH policies" again suggests tokenism or a kind of 
condescension which Herbert Marcuse has labelled "repressive tolerance" 
(that is to say, the appearance of liberality without its substance). Is 
the NIH so sure that its grantees and minions have all of the necessary 
wisdom in this area to fully assess the risks and make safety determinations 
regarding desirable courses of action? Is the government so completely pre- 
judging the regulations and their political implications that it offers 
merely one slot on the RAC as an act of charity and graciousness, to those 
who have deep concerns about the directions of the existing policy? 
In the areas of environmental policy and regulation, the courts have 
recognized the critically important role which citizens groups and environ- 
mental organizations have played in holding public officials to the highest 
standards of duty and in contributing to the substantive protection of 
environmental values; it is high time for the NIH and the Department of HEW 
to recognize that those among us who have been raising questions about the 
substance and administration of the regulatory procedures under which 
recombinant DMA research has been occuring have performed an important 
public interest service. Our membership and participation on the RAC and 
on institutional biohazards committees should be actively sought as a means 
of attempting to further achieve the goals of safe and effective policy 
making and regulation in this area. 
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