MEMORANDUM 
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE 
PUBLIC HEALTH SERVICE 
NATIONAL INSTITUTES OF HEALTH 
TO : Director, NIH 
DATE: April 9, 1976 
FROM 
. Associate Director for 
Program Planning and Evaluation 
SUBJECT: The Interagency Meeting on DNA 
As a result of your meeting with the agency representatives, a number of 
issues were raised that merit our further attention as you continue the 
plan for the release of the guidelines. These issues follow below: 
1. Of all the agencies represented at the meeting on Thursday it 
would appear that OSHA, EPA, and CDC have regulatory roles that 
may impinge on DNA recombinant research. The possibility of 
litigation, for example, might arise because of certain authorities 
these agencies have. Therefore, you suggested that we have a 
review of the jurisdictions to determine if we can have a more 
precise definition of their potential regulatory role in this area. 
You also asked that there be an analysis of Peter Hutt's recom- 
mendation concerning the public health legislative authority 
that gives CDC power to regulate infectious materials in interstate 
commerce. It should be noted that several of the other agencies 
were more than happy to accept our guidelines, and that is a 
most significant contribution from the meeting on Thursday. 
2. We reviewed possible NIH initiatives to alert private industry 
of the guidelines. It was agreed that you would call Roy Vagelos, 
Sid Udenfriend and Bill Hubbard. Dr. Jacobs would review other 
possibilities in private industry, including the drug industry. 
I will call Dr. Galler of Commerce to pursue with him further 
industry contacts. It was agreed that you should hold a meeting 
with private industry much as you did with the Government agency 
representatives. That meeting should be scheduled within the month. 
3. We discussed how to proceed internally on promulgating the guidelines. 
Within the next few weeks you should have a final version of the 
guidelines. I have contacted all of the people from whom you wanted 
ancillary material. You should receive most of it by next week. 
After you have reviewed that material you can make your final 
decision on the last few remaining points of contention with respect 
to the guidelines. Next week we should also review Emmett Barkley's 
implementation section to complete that section of the guidelines. 
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