Dr. Fredrickson 
Page Six 
the Guidelines themselves contain any requirement that the RAC 
include public members, much less any information about the basis 
upon which such members will be selected. Moreover, the concept 
of a separate public advisory committee has been rejected on the 
premise that the DAC adequately meets the need for public partici- 
pation at the national level. This premise misconstrues the role 
of the DAC, ignores the realities of the deicsion-making process, 
and subordinates the public interest to the tyranny of technical 
expertise . 
There can be no question that the RAC is the principal 
advisory body on recombinant issues. The DAC, with responsi- 
bilities over a broad range of subject matter, has neither the 
time nor the mandate to immerse itself in any but the most far- 
reaching of DNA research decisions, and cannot focus on even those 
decisions in the same depth as the RAC. Its members cannot be 
expected to develop the same range or depth of knowledge regarding 
complex DNA research issues as could public members who were 
included in ongoing oversight and continuing evaluation on the RAC. 
Moreover, DAC review comes at a very late stage of decision- 
making. As a result, its contributions will ordinarily be 
incremental and reactive, and the opportunity for constructive 
and creative interaction between public and scientific members is 
likely to be lost. Because the timing of participation in decision- 
making processes is so often crucial, there must be full public 
participation at each critical stage of that process. 
The Guidelines should be revised to include a requirement 
that a majority of the RAC consist of public representatives, and 
to assure that both scientist and lay members of the Committee 
reflect a balanced view of the public interest. Although additional 
consideration should be given to the particular constituencies and 
proportions which would best serve this purpose, the following 
model may provide a useful starting point: One third of the 
scientist members and one third of the lay members would be selected 
from among persons nominated by environmental organizations. The 
remaining two thirds would be selected from among persons nominated 
by the Environmental Protection Agency, NIOSH, the Center for 
Disease Control, an organization of research scientists, and an 
organization representing non-professional laboratory employees. 
In addition to these changes regarding the composition of 
the RAC, we urge that the guidelines be expanded to include 
detailed procedures for public notice and comment in advance of 
RAC decisions. 
Herbert Semmel 
President 
Mark Kleiman 
Executive Directo 1 - 
HS: vl 
cc: Peter J. Libassi 
[A-381] 
