10 
(4) Enforcement of the above requirements through monitoring, 
inspection, and sanctions. 
It was the conclusion of the Subcommittee that present law could 
permit imposition of some of the above requirements on much recombinant 
DNA laboratory research, but that no single legal authority or combination 
of authorities currently existed that would clearly reach all research 
and other uses of recombinant DNA techniques and meet all stated require- 
ments. Although there is existing authority that might be interpreted 
broadly to cover most of the research at issue, it was generally agreed 
that regulatory actions taken on the basis of any such interpretation 
would probably be subject to legal challenge. The Subcommittee, in 
reaching this conclusion, reviewed the following laws that were deemed 
to warrant detailed consideration: 
(a) The Occupational Safety and Health Act of 1970 (Public Law 91-596) 
(b) The Toxic Substances Control Act (Public Law 94-469) 
(c) The Hazardous Materials Transportation Act (Public Law 93-633) 
(d) Section 361 of the Public Health Service Act (42 U.S.C. 264). 
The full Committee adopted the report of its Subcommittee and agreed 
that new legislation was required. 
Interagency Committee Analysis of Elements for Legislation: 
In considering the elements for legislation, the Committee reviewed 
[ 836 ] 
