Director, Office of Recombinant DNA Activities 
February 1, 1984 
Page 3 
and they have established rules regarding its application. NIH 
committees treat as confidential certain portions of research 
grant proposals. Therefore, there is ample precedent for closing 
portions of RAC considerations dealing with such material, and we 
would encourage the continuation of this practice. The most 
important consideration is that, for the foreseeable future, the 
federal agencies with regulatory or enforcement responsibility 
would be seriously hampered in the discharge of their duties 
without the continued availability of RAC for consideration of 
issues they or the regulated industry, for example, consider 
important. Duplication of the functions of RAC among the several 
federal agencies has thus far been avoided; the public interest 
is well served by the existance of a single broad-based review 
group with demonstrated capability to deal with complex issues. 
IV. Should the NIH guidelines be limited strictly to biomedical 
research? 
Because of the importance of the transfer of knowledge from 
one field of application of the basic concepts of biotechnology 
to others, PMA believes that the activities of the RAC should not 
be confined to biomedical research. The Committee may feel the 
need for augmentation of expertise in areas not currently repre- 
sented by its members, but this would be preferable to the estab- 
lishment of committees in other agencies which would be similar 
to RAC with the attendant organizational redundancy, competition 
for resources (including intellectual), and the inevitable prob- 
lems of communication. 
PMA appreciates the opportunity to comment on these questions. 
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