-7- 
Mr. Walsh stated that the State Department had also submitted its comments 
to OMB and these included: (1) the addition to Section 3(c) (General 
Requirements) of a statement pertaining to national security and foreign 
policy; (2) that Section 11(a) (Disclosure of Information) also include 
the other sections of 5 U.S.C. 552; and (3) that the need for reference 
to Section 102(2) (c) of The National Environmental Policy Act (NEPA) 
and to 5 U.S.C. 553 in Section 4 (Standards) of the draft is questionable. 
Dr. Lewis explained that the executive council of the NSF was in the 
process of formulating comments for transmittal to OMB, but, in the 
process of discussing the draft with various staff members, the sections 
providing for criminal provisions and for the destruction of materials 
seemed to be particularly troublesome. 
The Defense Department has forwarded its comments to OMB, and Dr. Koslov 
explained that these included: (1) that the addition to Section 3 as 
offered by the State Department be accepted; (2) that the language of 
Section 11 needs to be more specific; and (3) that Section 8 (Inspections) 
be amended so that the investigator retains ownership of samples taken 
during inspections. 
Dr. Elder, FDA, pointed out the lack of an appropriations section in the 
draft, and the representatives from the Transportation Department and the 
Veterans Administration explained the position of their agencies that (1) 
State involvement in the regulation of recombinant DNA activities is vague 
and may conflict with the Hazardous Materials Transportation Act and (2) 
the Secretary is given too much discretionary authority, respectively. 
[ 358 ] 
