While EDF and NRDC commend the monumental effort made by NIH 
to regulate this potentially hazardous branch of research within 
its own jurisdiction, we are disturbed by the fact that the 
guidelines cover only NIH supported research, leaving large 
segments of the scientific and industrial communities subject 
to no required safety procedures. Recombinant DNA research and 
technology is now being pursued and supported by private corpora- 
tions, agencies of the Federal government, as well as scientists 
at universities and private institutions. 
General Electric is trying to develop a bacteria which can 
degrade petroleum and could be used to consume oil spills. 
Imperial Chemical Industries Ltd. (ICI) of Britain is trying 
to develop a virus which produces insulin. (Janice Crossland, 
"Hands on the Code", Environment 18:6, September 1976). The 
drug industry in the United States has also expressed interest 
in the commercial use of recombinant DNA techniques. Federal 
agencies such as the Department of Defense may contemplate 
conducting experiments. Scientists at universities whether 
they receive government grants or not are conducting recombinant 
DNA research. Therefore, we consider a uniform set of regu- 
lations covering all parties engaging in recombinant DNA research 
to be absolutely necessary. 
IV. The Secretary of HEW Has the Authority 
To Regulate All Recombinant DNA Activities 
Section 361 of the Public Health Services Act (42 U.S.C. §264) 
gives the Secretary of Health, Education and Welfare the authority 
to regulate all recombinant DNA research and technology. The 
Section empowers the Secretary to: 
"... make and enforce such regulations as in 
his judgement are necessary to prevent the intro- 
duction, transmission, or spread of communicafc-le 
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