- 8 - 
Mr. McGarity explained that comments of the EPA, transmitted to OMB by 
phone, noted two instances in which language recommended by the Committee 
had been omitted from the draft: (1) Section 3(c) does not include that 
the Secretary "defer" to the appropriate agency after consultation and 
(2) Section 12 (Preemption of State and Local Law) does not permit the 
drafting of standards which are identical to those instituted by the 
Federal government. In addition, Mr. McGarity cited the lack of 
provision for public participation and suggested that the exemption from 
the provisions of NEPA be deleted from Section 4. 
Dr. Lewis explained that the Agriculture Department has not yet formulated 
an official position. However, a committee representing the four agencies 
of USDA has drafted a letter to the Secretary of Agriculture stating 
that: (1) there is an apparent contradiction in the language of Section 
16 and Section 17; (2) the USDA needs some relief from Section 3(a)(4) 
of the guidelines which prohibits the deliberate release of recombinant 
DNA molecules from the laboratory; and (3) the USDA has problems with 
the amount of discretionary authority residing with the Secretary of HEW. 
Dr. Fredrickson explained that any substantive consnents he receives will 
be promptly forwarded to OMB and that the agenda for the next meeting of 
the Conmittee would include discussion of the following: (1) international 
activities and (2) institutional patent agreements. In regard to the 
former issue. Dr. Fredrickson asked all of the representatives to be 
prepared to describe the nature of their formal and informal contacts 
with research and regulatory bodies in other nations which might be 
relevant to the extension of policy concerning recombinant DNA activities. 
[ 359 ] 
