30 
experience as a regulator, although it is well qualified to propose stand- 
ards. Clifford Grobstein. Roy Curtiss, and Frank Young, among others, 
agreed with Director Fredrickson’s recommendation that inspection 
and enforcement authority be transferred to another agency in HEW, 
perhaps the Center for Disease Control, with its extensive experience 
in controlling infectious agents and supervising laboratory prac- 
tices. Grobstein saw merit in the creation of an independent regula- 
tory commission, but only in the long run, when the implications of 
genetic manipulations in the areas to extend beyond considerations of 
health and safety to applications in the areas of energy, agriculture, 
pharmaceuticals, the environment, and possibly human genetic 
engineering. 
Advisory system 
Criticisms of the Recombinant DNA Research Advisory Committee, 
the authors of the 19T6 guidelines and the proposed revisions, also 
focused on committee members’ involvement in recombinant DXA 
work and their relatively narrow expertise, as well as the National In- 
stitutes’ failure to encourage broad scientific and public participation 
in the standard-setting process. According to Jonathan King, among 
others, the advisory committee has been dominated by biochemists and 
molecular biologists skilled in the techniques of recombinant DXA 
and interested in their application but not expert in the assessment of 
their effects. He charged that scientists with relevant experience in 
public health, pollution, microbial ecology, and occupational health, 
for example, had “essentially been excluded from the proceedings.” 
Furthermore, the advisory committee’s reliance on unpublished data, 
communicated by letter and phone call, had contributed to “the abro- 
gation of the normal process of scientific decisionmaking.” 
Rov Curtiss, a current member of the advisorv committee, conceded 
that “in hindsight, it is clear that the guidelines could have been 
drafted with much greater public input.” To allay the criticisms 
which would become increasingly deleterious to science and society, 
he called on the scientific community to “entrust certain decision- 
making authority with representatives of society * * *” bv support- 
ing the establishment of two independent advisory committees. One 
committee, with responsibility for formulating physical and biological 
containment standards and reviewing applications for approval of 
host -vector svstems, would be composed of scientists in genetics, molec- 
ular and cell biology, infectious diseases, epidemiology, ecology 7 , 
agricultural science, industrial microbiology and other fields that are 
or might become relevant. A second committee, representative of “all 
segments of society” and possibly including scientists not engaged in 
recombinant DXA work, would approve or disapprove but not amend 
the proposed regulations, suggest how the regulations are to be im- 
plemented. and make ether recommendations based on a continuing 
evaluation of the social impact of recombinant DXA technology. 
Jonathan King endorsed this proposal, particularly its provision for 
a broadly representative committee to study longer range issues of 
"enetic research and engineering policy. 
Role of institutions enqaqed in research 
The XIH guidelines assign primary responsibility’ for approving 
the research facilities and procedures and for monitoring compliance 
[Appendix B — 289] 
