4 
was the question of whether the NIH Guidelines could be extended by 
the Commerce Department to non-f ederally supported activities. 
Dr. Galler, Commerce, replied that a voluntary surveillance program could 
be initiated, and he has informally contacted industrial representatives 
to explore their concept of what would constitute a satisfactory system. 
He added that such a program would be a very complicated one to implement. 
Dr. Barth, EPA, stated that compliance on a voluntary basis is laudable 
but too often a difficult goal to achieve even with legal enforcement 
powers. Mrs. Bastian, CEQ, reinforced this position and stated that, once 
safeguards are deemed necessary, voluntary compliance is no longer 
adequate. Dr. Galler stated that he was sensitive to Dr. Barth's 
position but noted that abuses will exist even with a regulatory 
process. Furthermore, many people in the private sector would welcome 
legislation to avoid a patchwork of inconsistent State/local statutes. 
Future of the Committee 
In the absence of legislation, Secretary Califano has asked the Committee 
to continue to serve as a forum for the discussion of recombinant DNA 
issues . 
Respectfully submitted. 
■Associate Director for Program 
Planning and Evaluation 
National Institutes of Health 
Bethesda, Maryland 20014 
November 10, 1977 
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