X. SUPPLEMENTAL VIEWS OF SENATOR E AGLETON AND 
SENATOR CHAFEE ON RECOMBINANT DNA 
While we agree that the potential risks, as well as the potential 
benefits, of recombinant DNA research dictate some form of Federal 
regulation, we have reservations about the independent Commission 
established in this bill to license, regulate and make policy decisions 
regarding recombinant DNA activities. 
As constituted in S. 1217, the Commission would be composed of 
11 members, appointed by the President, 6 of whom would be non- 
scientists, and 5 of whom are or were engaged in recombinant DNA 
research. Although the members would not be full-time employees of 
the Federal Government, they would be charged with the responsi- 
bility of directing all of the staff personnel of the Commission, pro- 
mulgating rules and regulations to implement the act, reviewing 
license applications, issuing licenses, monitoring compliance by li- 
censees, determining biological species which exchange chromosomal 
DNA by cellular recombinational processes, and contracting for the 
development of effective epidemiological methods. In our view, this 
wide range of responsibilities, and the technical nature of these re- 
sponsibilities, make such a Commission structure unworkable. In 
practice, most decisions would be made at the Commission staff level, 
and we question whether or not the Commission members would even 
be able to carefully review these staff decisions. 
An even broader concern goes to the establishment of independent, 
policy making bodies such as this proposed Commission. Although 
it can be argued that the regulatory range of recombinant DNA re- 
search is broader than the Department of Health, Education, and 
Welfare, we believe that the preponderance of such activity will fall 
within the traditional framework of the National Institutes of Health. 
Given HEW’s regulatory action in this area at the present time, it 
appears to me that it would be far better to vest the authority for 
recombinant DNA safety regulation in the Secretary of HEW, and 
to require that he establish an advisory committee. An advisory com- 
mittee, with a structure similar to that of the Commission in the 
committee bill, would assure adequate public and outside scientific 
input on all matters relating to recombinant DNA research. 
As presently drafted S. 1217 simply produces an added layer of 
bureaucracy, which, in our judgment, will not regulate the safety 
of DNA research as effectively as the Department, 
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