15 
non-voting member of the RAC. In addition, before the Director 
of NIH may execute any major action, the Director must provide 
an opportunity for federal agency -- and hence, EPA -- com- 
ment . 24/ 
c. The Current Regulatory Scheme Permits 
Adequate Review Of the Manufacturing 
Process 
EPA's final concern is that present regulatory authority 
does not permit review of chemical substances prior to their 
manufacture, nor for control over the manufacturing process 
itself. This concern, considering the overall regulatory 
scheme, also is not well-founded. Several statutes and sets of 
regulations already permit significant federal intervention 
prior to and during the manufacturing process. 
The Occupational Safety and Health Act grants authority to 
promulgate safety and health standards for workers. 25/ For 
"toxic materials or harmful physicial agents" the statute 
mandates that OSHA "set the standard which most adequately 
24/ Id . at 24561-62. Included in the definition of "major 
action" is any change in containment levels, assignment of 
containment levels for situations where none had been 
previously decided, amending the list of DNA molecules 
exempted from the Guidelines, and permitting any experi- 
ments that normally require RAC review and NIH and IBC 
approval before they may be initiated. 
25/ 29 U.S.C. § 651 et seq (1970). 
[715] 
