Fredrickson 
23 Sept 78 
5 
In addition to the coimients I have made earlier, I should 
like to make some on the present guidelines revisions. I think that 
there should be greater adherence to NEPA and OSHA. The reversal of 
the submission of the Guidelines before the Environmental Impact 
Report Is a clear violation of the law and was Inexcusable when 
coming from a Federal official like yourself, Dr. Fredrickson. 
The role of local State Health agencies should not be overlooked and 
utilized to the fullest. This Is not a matter of preemption, but simple 
utilisation of the best resources and thinking. For example, the a j 
simple notification of the local biohazards committee and the NIH 7 4 ' 
(Sec lV-A-4-h). 1 
Others have made recommendations with which I heartily concur. 
The establishment of a central registry of "accidents" might help in 
the drawing up of future revisions - either upward or downward depending 
on life's own experiences. Particularly I am concerned by the lack of 
sufflcent teeth and penalties In the sections dealing with non-compliance. 
Specifically there Is the matter of worker compensation and more 
partlculary the remedy of the situation which caused the difficulties in 
the first place. The history of occupational safety and health is 
replete with such deflcencles, and it Is not over with yet. And in 
this connection, I do not consider or put into a different category 
the Universities from private industry. 
Sincerely, 
M. Jack Frumln, MD 
Clinical Professor of Anesthesia 
Stanford U. School of Medicine 
cc: Senator A. Cranston. 
Rep Paul McCloskey 
Prof J. Brauman 
Prof B. Richter, NL 
[A-307] 
