Dr. Fredrickson 
Page Five 
Open Meetings 
The decisions of the IBC are sufficiently critical that all 
meetings should be open to the public. The Guidelines include no 
requirement that meetings be open, apparently because of the 
possibility that some portions of some meetings may involve 
discussion of proprietary information. See 43 Fed. Reg. 33065. 
Although the Decision of the Director does "urge . . . that local 
committees, when possible have open meetings and suggest that all 
meetings be announced," ibid, even these suggestions find no place 
in the proposed Guidelines. 
Regardless of whether HEW chooses to allow researchers to 
obtain patents on the results of NIH-funded research, it clearly 
has the authority to condition grants of federal money on agreement 
that all IBC sessions will be conducted in public. We question 
whether the interest in protecting proprietary information is 
sufficiently compelling to justify shrouding important IBC decisions 
in the secrecy of closed sessions. 
Moreover, it is absolutely clear that a decision to protect 
proprietary information cannot justify closing to the public 
those meetings at which no such information is presented. The 
Guidelines should require at a bare minimum that all IBC meetings 
be open to the public unless the committee votes to close a 
limited portion of a particular meeting at which proprietary 
information is to be discussed. 
Moreover, the Guidelines should specify procedures by which 
each IBC must provide public notice of the date, time, place and 
agenda in advance of its meetings. 
II. RECOMBINANT DNA ADVISORY COMMITTEE 
The responsibilities of the RAC, even more than those of the 
IBC's consist largely of balancing competing social policies and 
values. Decisions to revise guidelines, to certify host vector 
systems to establish exemptions or to permit exceptions to pro- 
hibited classes of experimentation can hardly be characterized as 
purely or even predominately technical in nature. Accordingly, 
it is imperative that the proposed Guidelines be revised to 
provide adequate public representation on the RAC and adequate 
opportunity for public comment at all stages of the decision- 
making process. 
The Decision of the Director indicates that the RAC currently 
includes two public members, that they "have served the public 
interest well and have done a superb job," and that more public 
members "may be added." Despite this recognition of the important 
role of public representatives, neither the decision document nor 
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