Dr. William J. Gartland, Jr. 
January 31, 1984 - Page 4 
We believe that it is entirely appropriate for the RAC 
to hold closed sessions where items of proprietary 
interest are discussed. 
The RAC has — as nonvoting members — representatives of 
all the relevant Federal agencies. These representa- 
tives interact with industry and other nongovernment- 
funded institutions on a daily basis. Problems of the 
retention of information of competitive and national 
security interest are routinely met in closed meetings 
of the Department of Defense, Environmental Protection 
Agency, Food and Drug Administration, Occupational 
Safety and Health Administration, United States 
Department of Agriculture, and others. Within the 
NIH, as well, such items as research grant proposals 
are treated as confidential materials during their 
reviews. Certain of these agencies have enforcement 
authority covering areas of application of this 
technology. They, also, have come to the NIH for 
expertise in this new scientific area because it is 
not available in their respective agencies. 
If a significant concern is the need for more direct 
input from the authoritative Federal agencies, we 
suggest that their representatives to the RAC be made 
voting members — or at least be charged with the 
responsibility for submitting formal comments on any 
proposal, the implementation of which would fall 
within 'the jurisdiction of their agency. The fact 
remains that industry, through the actions of its 
various IBC's, assumes responsibility for these 
applications as it has done historically in the use of 
other technologies. Duplication of the functions of 
the RAC among several Federal agencies has thus far 
been avoided. We believe that the public interest is 
well served by continuing to have a single review 
group with the demonstrated capability to deal with 
these difficult and complex problems. 
The assumption of these obligations on the part of the 
NIH and the RAC on a continuing basis offers— in our 
estimation— the best opportunity for scientific review 
both of new experimental proposals and of any other 
relevant finding or event with a real or potential 
impact on recombinant DNA technology. 
[ 635 ] 
