proposed revised guidelines nor did I hear anything meaningfully new. You 
emphasized that you were transferring to RAC much of the responsibility the PRG 
designate to the Director of NIH, but in essence you did not indicate an intention to 
delegate any authority to RAC. As I heard it, you merely indicated RAC has a 
wide range of areas within which it can make recommendations for consideration 
by the director of NIH. Similarly, I was not impressed with the enhanced roles and 
responsibilities implied in the suggestion that the approximately twenty agencies 
represented on the IAC designate liaison members to RAC. RAC meetings have 
been primarily technical in nature and will be even more so henceforth. It is a nice 
gesture to encourage all these agencies to join the research agencies that already 
have liaison members to participate in RAC meetings, but the suggestion must be 
recognized as only a gesture. 
The recent interagency meeting was a good vehicle to permit you to state publicly 
that there is general agreement among the agencies with your reaction to agency 
comments to the PRG, but it was not a good vehicle to discuss the PRG 
meaningfully. I suppose the purpose of the meeting was the former and not the 
latter. Nevertheless, it must be observed that experience of the last 2-1/2 years 
has taught us that procedural aspects or implementation of the guidelines are 
intrinsically linked to technical aspects of the guidelines and it is stacking the deck 
to use the IAC consisting mostly of nonresearch agencies to seek general 
agreement with the roles and responsibilities prescribed in the revised guidelines. 
To consider the NSF in the same light as Labor, Justice, Transportation, and other 
non-science agencies reflects an insensitivity that must not go unheeded. As NSF's 
senior scientist for recombinant DNA activities I had been a voting member of 
RAC during most of the period in which the current guidelines were developed and 
was moved to a liaison role to make a slot available for a nonscientific member. 
With this history, it is very unflattering to know you believe you are extending the 
role and responsibility of the NSF by permitting us to have a liaison member in 
RAC together with representatives from nonscientific agencies such as the naive 
person who asked for clarification about the difference between "recombinant 
DNA" and "recombinant DNA molecule" as referred to in different places in the 
PRG. It should not be necessary to explain to you the differences in roles and 
responsibilities between the NSF and DOT in our respective roles past, present, and 
future. Similar differences exist between NSF on the one hand and each of the 
other liaison agencies. 
In your telephone call to me on the morning of October 12, you stated that Dr. 
Atkinson's recommendation of an "interagency subcommittee" considering RAC 
recommendations would not work. Your concern was that EPA and OSHA would 
insist on being members of the subcommittee and this would complicate the 
process. But an IAC subcommittee is not a proper interpretation of the NSF 
recommendation. Representation of two or possibly three of the other research 
supporting agencies on your "kitchen cabinet" would be a more accurate 
interpretation of Dr. Atkinson's recommendation. It is important that you be 
exposed to points of view of agencies other than NIH when evaluating RAC 
recommendations. Further, an important part of Dr. Atkinson's recommendation 
that I emphasized at the meeting is the need to reduce the time lag between RAC 
recommendations and their implementation. If the NSF had representation when 
RAC recommendations were evaluated, and we understood the basis of postpone- 
ment of decisions, we undoubtedly would be more patient with the delays involving 
NSF supported research. 
[A-430] 
