Memo from To:

Phil Handler
JOSHUA LEDERBERG
em
33 TSCA

I agree that the legislation, if read as you
and I would prefer, responds to the most urgent
needs of the research community. But the admini-
strator has such enormous latitude-- my concern
is how to be sure he is well advised about that

flexibility.

I would urge you to inquire what advisory
mechanisms the EPA intends to employ in setting
up its draft regulations and definitions in this
area; and my hunch it would be a good idea to
establish or instruct a standing committee of
the NAS to be sure there is a well-informed group
with some authority, ready to speak at short
notice, There are always going to be some
incidents -- take the Pb (N3)5 that is now a hot
issue as an explosive residue -- that can be used
as a pretext or focus of pressure for more
restrictive approaches, such as ARE within the
administrator's discretion. The law is so tricky
that any scientific group is going to need very
careful briefing to avoid legal and bureaucratic
shoals in its arguments.

 

PROFESSOR JOSHUA LEDERBERG
Department of Genetics
School of Medicine

Stanford University

Stanford, California 94305