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Coalition 
RECOMMENDATIONS : 
1. RAC Committee : The committee should be redesigned to be advisory to 
DHEW rather than to NIH. Final decisions on control 
and management should be made by an office of HEW 
which is not involved in promoting recombinant DNA 
activities . 
2. Chairperson : The chairperson for the committee should not have close 
ties with any sectors involved in recombinant DNA 
activities. Such partisans cannot function impartially 
as is required for the responsibilities attached to the 
chair. 
3. Composition : The present committee is narrowly constituted as might 
befit a purely technical committee. Representation of 
fields other than technical fields is meager. All nom- 
inations have come from the NIH. The NIH foresees only 
"modest" expansion of membership "as needed for expert- 
ise" (p. 33051, Col. 1). The committee should be ex- 
panded to include representatives of unions representing 
technical workers in this field, representatives of pub- 
lic interest groups, and some individuals not aligned 
with specific sectors but with knowledge and experience 
in law, public policy, regulation of other technologies 
with broad social impact, and environmental protection. 
Members should be chosen in consultation with the agen- 
cies with potential regulatory jurisdiction in this area, 
namely, OSHA, EPA, CDC, and FDA. 
II. ?nopose.d TsianAteA Pximcviy Responsibility Compliance, to Local 
Institutions (p. 3 3044, Col. ll 
Thus far, controls on recombinant DNA research have been based largely 
on principles of self-regulation and peer review. Experience during the past 
year, at two prestigious schools, has shown that irresponsible or thoughtless 
actions do occur under this form of control. Yet the response of the NIH has 
been to propose to Increase , rather than to balance, the responsibilities of 
local institutions by transfering primary responsibility for control to those 
institutions and their biohazard committees (p. 33084, Col. 2). Under the 
proposed revisions, biohazard committees would be responsible for insuring 
compliance with the guidelines, and for medical surveillance, training, and 
the formulation of emergency procedures. Yet the IBC’s are required to have 
only token representation of non-professional laboratory personnel and persons 
not affiliated with the institution (one in each category). 
[A-285] 
