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it is reasonable to place risk determinations in the hands of 
the experts. Genentech would leave decisionmaking authority 
concerning release, as well as other recombinant DNA review, 
with the NIH Recombinant DNA Advisory Committee (RAC), the 
demonstrated authority on genetic engineering and recombinant 
DNA risk assessment. 
The expertise possessed by RAC is not so common as to be 
easily replicated. To require that NIH and the RAC cease 
evaluating non-research deliberate releases, therefore, would 
necessitate evaluation of commercial proposals by less 
qualified individuals, a system of dubious benefit to the 
public. Further, the representation of the relevant agencies 
and specialized experts on RAC makes redundant the proposed 
role for the interagency task force. 
Respectfully submitted, 
General Counsel 
Of counsel: 
Pierson, Ball & Dowd 
1200 18th Street, N.W. 
Suite 1000 
Washington, D.C. 20036 
[ 723 ] 
