6 
IV . Subcommittee Review of Existing Legislation 
At the November 23 meeting of the Interagency Committee, the Federal 
regulatory agencies also reported on their regulatory functions. Following 
that review, a special Subcommittee was formed to analyze the relevant 
statutory authorities for the possible regulation of recombinant DNA research. 
All regulatory agencies were represented on the Subcommittee, assisted 
by attorneys from their offices of general counsel. (See Appendix II for 
the membership of the Subcommittee.) The Subcommittee held meetings on 
December 13, 1976, and on January 11 and February 8, 1977. 
The Subcommittee was charged to determine whether existing legislative 
authority would permit the regulation of all recombinant DNA research in the 
United States (whether or not Federally funded) and would include at least the 
following regulatory requirements: 
(1) review of such research by an institutional biohazards committee 
before it is undertaken, 
(2) compliance with physical and biological containment standards 
and prohibitions in the NIH Guidelines, 
(3) registration of such research with a national registry at the 
time the research is undertaken (subject to appropriate 
safeguards to protect proprietary interests), and 
(4) enforcement of the above requirements through monitoring, 
inspection, and sanctions. 
It was the conclusion of the Subcommittee that present law could 
permit imposition of some of the above requirements on much recombinant DNA 
laboratory research, but that no single legal authority or combination of 
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