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Under Section IV, the RAC is charged with the responsibility 
for recommending revisions of the Guidelines, recommending 
the certification of certain host-vector systems which meet 
established criteria, resolving questions concerning poten- 
tial biohazards and adequacy of containment, and recommend- 
ing exemptions from specific requirements. The PRG's state 
that NIH is considering additional public members on the 
RAC and that you are formalizing the procedures for the 
selection of such members. I recommend that you consider 
more public members, as well as members representing other 
scientific disciplines such as epidemiology, ecology, 
environmental health, and risk assessment. 
Because of our agency's role in worker protection, we have 
attempted to follow the development of the Guidelines. We 
have a strong interest in the Guidelines as well as their 
interpretations. To facilitate this, I recommend that OSHA 
be named as a full member, or as a Liaison Representative 
to the RAC such as those from other Federal agencies. Our 
representation should also be of benefit to NIH, as you will 
will soon be handling research protocols from the private 
sector, including proprietary information from industry. 
The "Laboratory Safety Monograph - A Supplement to the NIH 
Guidelines for Recombinant DNA Research" is a very well- 
written and valuable addition to the Guidelines. However, 
since it is the intention of NIH that the procedures out- 
lined in this book be followed to insure the integrity of 
the Guidelines, I urge that the provisions be mandatory 
rather than advisory in nature. In this way, strict 
enforcement and uniform interpretation of the procedures 
can be guaranteed. In the event that the special condi- 
tions of a facility warrant different procedures than those 
outlined in the Monograph, NIH could grant such a waiver 
following your review of the alternatives proposed. 
You state on page 33128 that grievance procedures for work- 
ers under the Guidelines were requested but "not considered 
necessary, as the rules and regulations of the Occupational 
Safety and Health Act already provide such a mechanism." 
You are correct that the Act would apply in most situations 
and that a worker's right to file a safety or health complaint 
is provided for under that Act. The Act also provides that no 
employee may be discriminated against for exercising his or 
her rights under the Act. However, as stated earlier, the OSH 
Act does not cover employees in State or local government 
institutions, unless that State has a State plan approved by 
OSHA. Since only 23 States have such plans at this time, it 
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