Recombinant DNA Advisory Committee - 10/16/90 
ensure consistency across all the agencies in the way that they 
are approaching the industrial sector. 
Dr. Ralph Yodaiken, Senior Medical Advisor at the Department of 
Labor (DOL) and the Occupational Safety and Health Administration 
(OSHA) suggested that DOL and OSHA also be made a part of any 
interagency committee that is developed to review this proposal. 
He asked what procedures were in place for reporting accidents 
and for follow-up of persons who are accidentally exposed. 
Dr. McGarrity said that the table associated with Appendix K will 
not contain any such requirements for the BLl-LS level. 
Dr. Joseph Van Houton, of the Robert Wood Johnson Pharmaceutical 
Research Institute said that the reason medical surveillance is 
not required at either the GLSP or BLl-LS level is that the 
organisms being addressed are non-pathogenic. He said that 
beginning at the BL2 level opportunistic pathogens are involved. 
Since such organisms pose a risk of infection, medical 
surveillance is required. 
Dr. Yodaiken noted the requirement under OSHA regulations for 
reporting hospitalizations on an OSHA log. He asked if there 
were written procedures for follow-up contained in the NIH 
Guidelines or whether each individual facility is left to develop 
its own procedures. 
Dr. McGarrity said no detailed procedure is outlined but that 
Appendix K-II-J states: 
"Institutional codes of practice shall be formulated 
and implemented to ensure adequate control of health 
and safety matters." 
Dr. McGarrity noted the historical desire of the RAC not to 
become involved in industrial practice. He briefly summarized 
the history of the RAC in dealing with industrial experiments in 
the early 1980s in which proprietary data were looked at in 
closed executive sessions. He noted that the NIH Guidelines had 
been revised since that time to generally state that all 
environmental laws should be adhered to and that there should be 
follow-up on all health and safety matters deferring, when 
appropriate, to the appropriate Federal regulatory agencies. 
Dr. Schaechter said that the EDF had been the only real 
dissenting voice in the discussion and he wanted to address some 
of the points they had made in their statement. He noted that 
the role of RAC and its overlap with other Government bodies has 
been the subject of concern. In fact, this had been an item of 
discussion in the regional hearings that the RAC had conducted 
Recombinant DNA Research, Volume 14 
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