UNIVERSITY OF WASHINGTON 
SEATTLE, WASHINGTON 98195 
20 January 1987 
Recombinant DNA Advisory Committee 
ORDA 
NIAID 
National Institutes of Health 
Bldg. 31, Room 3B-10 
Bethesda, MD 20205 
Dear RAC Members: 
I wish to comment on several aspects of the proposals In the Federal 
Register for December 19, 1986 which you will be discussing at your February 
2, 1987 meeting. As a threshold issue, let me express concern that your 
Committee and its subgroups appear to be getting a very skewed range of input 
on their proposals and work. The procedures of the Federal bureaucracy are 
such that the Register reaches most people only a few days before comments are 
due, a process which largely precludes reflective commentary. Only if one is 
on an "inside track" will it be generally possible to provide effective input, 
and that requires a presence in D.C. and/or lobbyists or paid staffers to 
monitor meetings, etc. 
In other words, your current procedures do not facilitate the receipt of 
a balanced range of views, and instead favor the over-amplification of the 
positions of private interests with means and of the bureaucracy itself. For 
example, none of the non-member attendees at the December 5 meeting of the 
Working Group on Definitions represented public interest groups. Do you 
honestly believe that no environmental organizations, to give but one example, 
have any interest in deliberate release? I urge you to promptly devote some 
attention to improving your outreach activities and assuring that interested 
persons have, in fact, enough time to respond to your proposals so that 
publication in the Federal Register is not just a sham legal formality. 
I was mailed the minutes of the December 5th meeting in response to a 
phone call several weeks ago to obtain information for constructing meaningful 
comments. These arrived on January 13th with a cover note from an ORDA 
staffer requiring comments to be received in Bethesda on January 14 if they 
were to be available for "prior review" by RAC! 
Recombinant DNA Research, Volume 1 1 
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