SINCE 1925 AN INDEPE' "NT NON PROFIT ORGANIZATION [>l VOTED TO 
THE PRESERVATION DISTRIBUTION OF REFERENCE CULTURES 
American 
Type Culture 
Collection 
12301 PARKLAWN DRIVE ROCKVILLE. MARYLAND 20852-1776 USA (301) 801-2600 TELEX: ATCCROVE 908-768 
January 31 , 1 984 
Dr. William J. Gartland 
Chairman, RAC 
National Institute of Allergy 
and Infectious Diseases 
National Institutes of Health 
Bui 1 di ng 31 , Room 3B1 0 
Bethesda, Maryland 20205 
Dear Doctor Gartland: 
This letter is in response to the request for comments on Boundaries 
for NIH and RAC Oversight asked for by Dr. Talbot in the Federal Register, 
Volume 49, #3, January 5, 1984. 
By virtue of its leadership and professional handling of recombinant 
DNA issues, the RAC has succeeded in becoming the focal point for recombinant 
DNA policy issues in the U.S. and the world. 
It appears that not only Nature but the general scientific community 
as well abhor a vacuum and a greater variety of issues are being brought to the 
RAC for resolution than its founders intended. 
In my opinion it would do great mischief to restrict the boundaries of 
the RAC severely and given the absence of like-chartered overview committees 
in other agencies I suggest the RAC allow itself to be used as an honest broker 
for various agencies to determine the venue of particular problems submitted to 
it. 
It would work a great hardship on the scientists who serve as expert 
consultants to be impressed into serving on multiple agency committees and if 
the past practice of forming ad hoc subcommittees is continued the variety of 
issues could be efficiently handled. 
While laboratory work was the genesis it is not difficult to extend the 
need for concern about practical applications in the field. The RAC could make 
sure that agencies with official responsibility for regulation or surveillance 
are coordinated into the review process. Those agencies awareness and acceptance 
of surveillance responsibility could well be the deciding factors in a project 
getting RAC permission. 
[630] 
