- 2 - 
is both proper and necessary exercise of oversight in the 
national interest- Therefore, we believe that RAC should not 
limit the NIH Guidelines strictly to work done in the laboratory. 
Applying the Guidelines and RAC oversight of field testing of 
rDNA applications outside of the laboratory is a necessary step 
in the evaluation of this technology and government oversight 
to assure public safety and health. 
Comment has also been solicited as to whether or not 
NIH should limit its review to proposals funded by NIH or the 
Federal Government. Du Pont urges NIH to continue to review 
proposals for rDNA work that arises under private sector funding 
as well as those which receive government funding. It is con- 
sistent with the history of this country that as research moves 
from the bench to practical application, private sector funding 
is the flywheel that enables this to occur. Such has been happen- 
ing in the field of biotechnology with a substantial influx of 
private capital to support development of practical applications 
and continued research on rDNA. It is our position that NIH has 
provided effective guidance and oversight to assure that appli- 
cation of biotechnology is done safely. It is our view that 
continued involvement of NIH in an oversight role would be 
necessary until such time as other agencies develop the needed 
expertise and resources to supplement the role of NIH. We 
further urge that NIH lend its assistance and guidance to other 
agencies of the Federal Government to assure appropriate coordi- 
nation in the oversight of rDNA research and development to 
assure consistency in approach. 
We have been asked to provide comment as to whether 
or not all portions of the RAC meetings should be open to the 
public. We support the practice that has evolved whereby RAC 
has accepted confidential information and has met in confidence 
with the affected parties when discussing large-scale proposals 
from industry. We do, however, recognize the interest of the 
public in access to information about field testing of new 
organisms. Therefore, RAC should encourage that companies 
minimize the scope of confidentiality claims and where confi- 
dential treatment is requested, provide a nonconf idential 
description of the work under review. Adoption of such pro- 
cedure will provide the needed protection but also permit the 
public to be aware of the nature of the work being reviewed 
by RAC. 
The last question posed in the Federal Register 
notice is whether the NIH Guidelines should be limited strictly 
to biomedical research. It is our view that NIH Guidelines 
should be applied to rDNA work in general and that, as the 
technology develops, the Guidelines be further refined as they 
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