Implementation of the Technology Transfer Act: A Preliminary Assessment

Published by the Government Accountability Office on 1990-05-03.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                      United States General   Accounting   Of&e

For Release           Implementation     of    the Technology     Transfer
on Delivery           Act:   A Preliminary        Assessment
Expected at
9:30 a.m. EDT
May 3, 1990

                       Statement  of
                       Michael J. Wargo, Director
                       Physical  Systems Evaluation
                       Program Evaluation  and Methodology           Division
                       Before the
                       Subcommittee  on Science,    Research, and
                       Committee on Science,     Space, and Technology
                       House of Representatives

GAO/T-PEMb - 90 - 4                                                     GAO Form 160 (12/87
         MR. CHAIRMAN AND MEMBERS OF THE SUBCOMMITTEE:                                                      I welcome           this
opportunity            to contribute                 to    the     Subcommittee's                    deliberations              on
using      our    nation's           basic         and applied                research          to improve            our
competitiveness               in world             markets.                The process             by which        scientific
research         and development                   is     transformed                into     commercially             viable
products         and services               has come to be known as "technology
transfer."             The Congress                has long            recognized             that     one way to
improve        technology            transfer             is     to draw upon the basic                        scientific
research         and development                   strengths               of our        federally          supported

         In    the     following            testimony,             we present                (1)     a brief        summary of
the     legislative           history           of      and congressional                     interest         in federal
technology            transfer,           (2)      background               information              on how we
developed         a reporting               system         to collect                information            on federal
agency        and laboratory                implementation                    of     the     legislation,             (3)
examples         of    the    types         of analyses                that        are      possible        with      the   data
collected         using       this        system,          and        (4)     concluding             observations.


         In 1980,           the Congress                passed         the     Stevenson-Wydler                    Technology
Innovation            Act    (Public            Law 96-480)                and amended it               in 1986 with             the
Federal        Technology               Transfer          Act      (Public           Law 99-502).              This
legislation            was passed,               in part,             to     (1) establish              a technology
transfer         mission          for      federal             agencies            and their         research         and

development               laboratories,                  (2)    improve              the    use of federally                       funded
research          and technology                   by,     among others,                    state         and local
governments,               and the private                     sector,          (3)        provide         federal              employee
recognition               for     outstanding              contributions                    to technology                  transfer,
and     (4) ensure               the     full      use of         the     products              of the           federal
investment           in research                 and development.                          The act         also         mandated         the
establishment                   of offices             of research              and technology                     applications
(ORTAS)          within          major       federal           laboratories                 and required                  the     set-
aside      for      technology               transfer           of not          less        than      0.5 percent                 of each
agency's          research             and development                   budget.

          In addition,                 the      Federal         Technology                 Transfer             Act,     as
implemented               by Executive                 Order      12591,         directs            department                and agency
heads      to authorize                  their         government-owned,                     government-operated
laboratories               to enter             into      cooperative                 research            and development
agreements            (CRDAs) with                 state        and local              governments,                    universities,
and private               companies;             award         exclusive              licenses            for      patents          to
cooperators               with     federal             laboratories;                   grant        awards             to federal
employees           significantly                  contributing                 to technology                    transfer;           and
implement           royalty            sharing          programs.               The act            also         institutionalizes
the     Federal           Laboratory             Consortium              for     Technology                Transfer              (FLC)      and
requires          agencies             to contribute               to     its         funding.

          The Congress,                  in general,             and the              House Committee                     on Science,
Space,      and Technology,                      in     particular,              have an understandable
interest          in determining                   whether         the         act     as amended is producing                              the
intended          results          and whether                 new legislative                     initiatives                are    called
for     to further               enhance         the      technology                 transfer         process.                My

testimony        is directed          toward       satisfying             these        needs.

           In June 1988,        the    House Committee                   on Science,               Space,       and
Technology         asked      GAO to examine            the        implementation                  of the Federal
Technology         Transfer       Act of       1986.             In response           to    that      request,           we
reported        that

          "We believe       it is too early          to determine        the impact the act
          has had on technology            transfer.        Further,       although      agencies
          reported     undertaking        numerous technology            transfer      activities,
          the activities         are defined      differently        and, consequently,
          uniform    statistical        information       has not been available                to make
          a comprehensive         evaluation.          To resolve      this problem and
          facilitate      evaluating       the impact of the act on technology
          transfer,     we are conducting            a separate      review to develop
          criteria     for reporting         technology       transfer      activities.”
          (Implementation         Status of the Federal             Technology        Transfer     Act
          of 1986, GAO/RCED-89-154,              May 1989, p.2).

          Congressman         Roe, Chairman            of    the House Science,                       Space,        and
Technology         Committee,         indicated         that        he believes              it     to be of
paramount        importance        to have at hand valid                        data        by which           to   judge
agency       implementation           and the       effect          of    the     Federal           Technology
Transfer       Act.        In September         1988,        the     House Science,                   Space and
Technology         Committee       asked       us to develop               criteria               and standards               for
obtaining        comparable        data     on technology                 transfer           activities             of
federal       agencies        and their        laboratories.

           In response        to the Committee's                   request,        we took            the      following
steps.        First,       we developed         a data           collection            system         designed           to
collect       comparable        data      across       agencies           and their               laboratories
relating        to their       implementation               of     the    act     and its           effects;          and,

second,          we demonstrated                  the     feasibility              of    using         the      system        by
attempting          to collect              data         from     27 federal             agencies            and 338 of
their      laboratories.


          We based         the development                     of our data              collection              system        on a
review        and analysis             of     (1)        technology           transfer              legislation           and
literature,              (2)     agency       and laboratory                  reports           to the Office                 of
Management          and Budget              and the            Congress,           and        (3)    interviews           with
department,              agency,       and laboratory                   officials.                  The analysis              and
synthesis          of     this      information                resulted         in      the     development              of    a
framework          for     data      collection                that     was intended                 to provide           the
Congress          as well         as the          executive           branch          with      data      for      use in
assessing          the         implementation              and the           effect          of the Federal
Technology          Transfer           Act.

          This     framework           formed            the    structure             from      which        we established
data      needs.          Identified              data     needs        in    turn       guided         our development
of      two questionnaires                  for     data        collection.                  We pretested            the       two
questionnaires,                  one for          laboratories               and one for               agencies,          during
April      and May 1989.                We then            revised           the      questionnaires                on the
basis      of the         pretest         findings.

          In June 1989,              the      House Committee                   on Science,               Space,         and
Technology          asked         us to pilot              test       our data           collection               system.            We

sent      advance         copies          of     the     questionnaire                to designated                 agencies
and their          laboratories                  to familiarize                   them with          the questionnaires
and to solicit                 their         comments            for       improvements.                In November               1989,
we mailed          revised          questionnaires                      to 25 agencies               within         federal
departments,              2 independent                      agencies,           and 338 of          their
laboratories.                  Our sample               included            cabinet-level               departments               and
federal      independent                  agencies             that        conduct       or    fund      research,
development,              or engineering.                       This        group     was composed of                  the
departments              of Agriculture,                      Commerce,           Defense,          Energy,         Health         and
Human Services,                   Interior,             Transportation,                  and Veterans               Affairs,            as
well      as the National                    Aeronautic                and Space Administration                        and the
Environmental               Protection               Agency.               As of April           27,     1990,
questionnaires                 were received                   from        21 (77.8       percent)            of    the      27
federal      departments                  and independent                    agencies          and 302 (89.3
percent)          of     the      338 laboratories.                         Appendix          I lists         the    agencies
and laboratories                   that         have returned                their       questionnaires.

          We expect            the eventual                   return        of almost          10Q percent             of      the
questionnaires.                    However,             it     will        probably       be another               2 months
before      all         responses              are     received.             Despite          the      incomplete            data       at
hand,      we carried              out         some preliminary                   analyses          and formulated                  some
tentative              conclusions,              which         we will           share    with        you today.               Please
keep      in mind          that        the      conclusions                are    tentative           and that         a final
report      based          on the         full         data      set       and a more thorough                     analysis          will
be produced              later.


         On the         basis        of our        experience             and analysis                    to date,       it
appears        that      we have been successful                            in developing                     a data
collection            system         that      should         provide           the Congress                  as well         as the
administration              with       reasonably              sound and fairly                         extensive        data
across        federal       agencies             and their              laboratories.                     Further,       we have
also       been successful                  in demonstrating                    that         the       system     can be
implemented             on a national               basis          and that            it     appears           to provide        much
more comparable                 and representative                       data      relating               to federal           agency
and laboratory              implementation                    of       the Federal                Technology           Transfer
Act    than     available             before.            Finally,           when fully                  analyzed,        these
data       should       provide        a baseline              for       assessing                 improvements          in
Federal        Technology             Transfer           Act       implementation.

         The following                preliminary              results           of         an analysis           of partial
questionnaire             returns            is presented                to provide                 the     Subcommittee          with
an illustration                 of the         richness            of    the data             collected           in our
demonstration             of the            viability          of our data                   collection           system.
These       results       also        provide           the    Subcommittee                   with        some preliminary
insights        regarding             federal           agency          and laboratory                    implementation              of
the    act,     as well          as early           data       on some of                   the     act’s       apparent
effects.            Cur results              are    discussed              in terms               of    the
characteristics                 of    the agencies                 and laboratories                       responding           to our
questionnaire,              their           implementation                of various                   provisions        of     the
act,     and measures                of effect.

         Our analyses             reflect        196 laboratory                questionnaires             that        had
been entered           into       our data        base as of April                   27,     1990.       This
represents        about          58 percent          of all         laboratories             to which      we sent
questionnaires.                  Another       le6     laboratory-level                   questionnaires              are
being     entered         into     our data          base.          Thirty-six            laboratories           and six
agencies       have not           yet     returned       their         questionnaires                to GAO.


         An initial            indicator         of whether            federal           agencies       have
encouraged        their          laboratories           to        implement         the major         provisions            of
the Federal           Technology            Transfer         Act      is to consider             the     answers
that     laboratories             provided        to    the        following         questions          posed        in our
survey      instrument.

         To begin        with,       we asked          the        following         question

         Question        8:             Has your laboratory            received      final    written
                                        instructions         from your agency for implementing
                                        any or all parts of the Federal                    Technology
                                        Transfer       Act of 1986?
                                        1.      Yes.      Final   instructions         were received.
                                        2.      No. However, draft             instructions        were
                                                received.        (29)
                                        3.      No instructions          have been received.            (48)

         The numbers             in parentheses              represent             the    number of
laboratories            that      responded          to question              8.     This      question         was
answered       by 187 of           the      196 laboratories                   in our       analysis.           As

indicated             by the      numbers          above,         3 years           after       the Federal
Technology             Transfer           Act was signed                  into      law,       about      26 percent          of
the     laboratories              still       report          not        having      received           any instructions
from     their         agencies.

         A second           indication             of agency              and laboratory                responsiveness              to
the objectives               of the         act     are       the        responses           to our question               about
the     location         of the mandated                  Office            of Research            and Technology
Application.                The act         states         that          each      federal       laboratory           shall
establish             an Office           of Research             and Technology                 Applications.                The
primary          function         of an ORTA is                to disseminate                   information           on
federally             owned or originated                     products,             processes,            and services
having       potential            for      transfer           and to assist                  in linking        the     research
and development                resources            of     the          federal       laboratories            to state         and
local     governments              and to the              private           sector.            ORTAs are           intended        to
serve       as the       bridge           from     laboratories                   to the       outside.        If     the ORTAs
are     to be effective,                   then,       they       need to be close                     to laboratories.
The question             we posed was

         Question           43:           What is the location        of the ORTA, or office
                                          that functions       as an ORTA, that your laboratory
                                          manages or controls?
                                          1. Within     your laboratory.      (37)
                                          2.   At agency     headquarters.    (128)
                                          3. Other.       (16)

         Based on the               data      collected                 to date,         the    numbers       in
parentheses             indicate           that     only       about            20 percent         of ORTAs are
located          in    laboratories.                 Rather,             they      are      located       mainly      at
agency          headquarters.                 This       is something                 we believe           should            be
carefully             considered.               If      the     successful             transfer          of technology
requires             close       and frequent                contact            among the           players,       then           the
ORTAS need to be close                          to the          laboratories.

          The Federal                Technology              Transfer           Act    authorizes              agencies            and
their          laboratories             to develop              cooperative                 research       and development
agreements              (CRDAs) with                 state      and local             governments,              universities,
and private              industry          to facilitate                   the     transfer           of technology                     from
federal           laboratories             to those             units.            One purpose            of the act                was to
facilitate              technology            transfer              at    the    grass        roots      or     laboratory
level.           The act            therefore          allows            departments            and agencies                 to
delegate             authority          to enter             into        CRDAs to their               laboratories.
Question             19 in       our    laboratory             questionnaire                  reads      as follows:

          Question            19:        Has your laboratory  received    authorization                                                  from
                                         your agency for approving     CRDAs?
                                         1.   Yes.  (71)
                                         2. No.    (109)

          Of the         180 laboratories                     that        answered           this     question,              about        61
percent          have not            received          authorization                  for     entering          into         CRDAs on
behalf          of    their       agency.

          If     we now move on to another                                aspect       of     implementation,                     we note
that      the        Federal         Technology              Transfer           Act    is     explicit          in requiring
each agency              with        annual          research            and development                 (R&D) expenditures
of more than                 $50 million              to establish                an awards           program          for        its
scientific          and technical             personnel           who have made contributions                            to
technology          transfer         activities.              Of the    21 agencies                 that        have
responded          to our      agency       questionnaire,             each      had an R&D budget                      of
more than          $50 million            in fiscal        year     1989.        However,            not        even half
of      these   agencies        had implemented                a technology              transfer           awards

          However,      we collected                information        that      indicates               that     some
laboratories           appear        to have established                their       own awards                  programs,
irrespective           of whether           their       agencies       had a program.
Specifically,           question           9 of our        laboratory           survey           instrument            reads
as follows:

          Question      9:           Does your laboratory       give an award (separate
                                     and distinct      from any such awards given by your
                                     agency) to reward scientific,            engineering,   and
                                     technical    personnel    for activities        leading to
                                     the filing    of patent     applications      or the award
                                     of patents?
                                     1.     Yes.    (41)
                                     2.     No, but plan to begin giving           such awards.
                                     3.       No, and do not            plan       to.           (128)

          Of the     191 laboratories                 responding        to date,            it      is apparent
that,      while     many laboratories                  neither      have nor plan                  to have         such a
program,        41 (or       about        22 percent)          currently         give       awards          for     filing
and receiving           patents       --one         notable       technology         transfer              activity.

          Also        dealing            with         implementation                      is question          92, which           asks
the     fOllOWing:

          Question             92:         Regarding     promotions      of your scientific,
                                           technical,     and management personnel,             does your
                                           laboratory     have any guidelines          that
                                           specifically       recognize     technology      transfer
                                           activities     or accomplishments         as one factor     on
                                           which promotion        decisions     may depend?
                                           1.     Yes.   (41)
                                           2. No.       (145)

          Note        that        this      question                does not             assume that           technology
transfer          activities                and accomplishments                             are     the     single        factor          on
which          promotions            rest;            it        asks     only       if     there      are     guidelines            for
establishing                 these        activities                   as one factor.                  Of the         186
laboratories                 that        chose             to answer            this       question,          78 percent            said
"NO . "


          It     is     too       early         yet         to assess            the       effect      of     the act        on the
actual          transfer            of research                    and development                  from      federal
laboratories                 to various                    other       sectors            of our      society.            However,             we
developed             several            questions                 designed              to compare         selected         measures
of    effect          at      two times--                  in    1986,      when the Federal                   Technology
Transfer           Act       was enacted,                       and in      1989.           Our measures              are    indirect
indicators              of       underlying                 technology              transfer          processes.             One such
variable           is      the      number of patents                           issued        to    federal          laboratories               or
their          personnel.                As mentioned                    earlier,           some provisions                 of     the     act

were designed                  to stimulate                      and reward               inventive         creativity.

          Question          69 and part         four        of Question               68 of our        laboratory-
level      survey       instrument           ask:

          Question          69:       During FY 1986, how many patents            were issued
                                      for inventions      arising   from your laboratory
                                      research    or development      work?
                                                 Number of patents      issued from your
                                      laboratory    during     FY 1986.     (317)

          Question          68:       During    FY 1989, please indicate      the following:
                                                 Number of patents    issued from your
                                      laboratory    for inventions    arising    from your
                                      laboratory    research   or development      work.

          The lack          of    increase      in     the    number           of patents           issued      in    1986
and 1989,           specifically             314 and 317,            is disappointing.                      In effect,
there      has been no change.                      However,         the       time     elapsed        between        1986
and 1989 may simply                  be too         short     to reflect               the   real     effects         of    a
changed       environment             for    patenting.

        Another         part       of Question             68 asks        about        the   number of patents
pending       for      innovations           arising         from        laboratory          research         or
development           work.         We found         that     many laboratories                     that     had not
reported          patents         granted      in    1989 actually                had patents              pending     in
that      year.        Unfortunately,               data     are     not       available        concerning
patents       pending            in 1986.       Information               of    that     sort       was not
maintained           by the        laboratories,             so we could               not   make a relevant
comparison           between        patents         pending         in    1986 and patents                  pending        in

         At present,             however,          it     is     too     soon to say much about                    the
act's      effects,           so there          is a need be very                     careful       about      drawing
conclusions            from      the data.               Since        our    own data           collection        is
incomplete,           we really           have no basis                  yet       to say whether             the number
of patents            issued      is likely              to    increase            as a result         of the      act.

         The legislation                 also      encourages               federal       laboratories            to enter
i'nto    licensing            arrangements.                   We assessed             responses        to this
provision         by comparing              the         number        of exclusive              licenses       granted          in
1986 with         the      number granted                 in 1989.             Here we found               8 cases       in
which      the    number of exclusive                         licenses         granted          in 1989 was less
than     the     number        granted          in 1986;          11 cases            in which        there      was an
opposite         result;         and 136 cases                 where        there      was no difference                 in the
number      of exclusive                licenses          in 1986 and 1989                  (most of these               were
cases      in which           no exclusive               licenses           were granted             in either         year).

         We also        made a comparison                      between         1986 and 1989 with                 respect
to nonexclusive                licenses.                The results            were similar            to those
described         above,         with     no change              in most cases              from      1986 to 1989
and with         most      responses            showing          no nonexclusive                  licenses       granted             in
either      year.

         However,          the    picture           is very            different         when royalty            income
rather         than    patents          and licensing                  agreements          is considered.

Question         63 of       our      laboratory-level                 survey         instrument           asks,          among
other      things,         the      following:

         Question          63:         In FY 1986 and 1989, what amount of royalty
                                       income did your laboratory          receive      (1) from
                                       your agency and (2) directly            from licensees     for
                                       laboratory    developed    innovations?
                                                    FY 1986 total      royalty      income received
                                       directly   from licensees.         ($176,000)
                                                  FY 1989 total      royalty      income received
                                       directly   from licensees.         ($1,683,200)

         Thus,       the     data      show that            with     about       $1.7    million         in 1989,
laboratories            were clearly               outperforming              their       1986 "selves"                   when
only     $176,000          were       received.             The increase              in royalties              from        1986
to 1989 represents                   a tenfold             increase.          What is notable                   is       that
this      increase,          which        is clearly           important          even though            it         is
measured         in current            dollars,           came about          during         a period           in which
the     number       of patents             issued        and the       number of            licensing              agreements
remained         constant.             When we have                received       all    our     data         and have
completed         our      analysis,             we hope to          shed more light               on this               issue.

         The framers               of the        act     were also        concerned            about     the         overall
coordination            of        technology            transfer       nationwide--across                     all        federal
laboratories.                It     was    for     this      reason       that     the       legislation                 gave the
Federal      Laboratory              Consortium             a statutory           charter.             The

organization            that        was formally             chartered           by the        Federal         Technology
Transfer         Act    was actually                   organized       in 1974.          All     major          federal
laboratories            and centers,               and their           parent      agencies,            are
automatically              eligible          for        membership        in FLC.            The mission                 of FLC

is    to promote              the    rapid      movement            of    federal         facility         research
results       and technologies                     into     the mainstream                 of     the     U.S.     economy.

          In Question               75, we asked            this:

          Question            75:       Does your laboratory       have a representative                                    to
                                        the Federal     Laboratory   Consortium   (FLC)?
                                        1. Yes.      (34)
                                        2. No.      (154)

          Thus,     our        preliminary             findings           here      are    that      most        laboratories
(82 percent)              do not        have a representative                          to FLC.           In addition,
responses          to some other                 questions           make it           clear      that     many
laboratories              do not        draw upon the                services           FLC provides              (for
example,          FLC's        electronic           mail      system         and its           Clearinghouse             data


          Although            the United          States       has been and continues                            to be very
strong      in fundamental                    scientific            work,        our    output       of
applied       research              and development                 is    another         matter,         whether
measured          in terms           of patents,            technological                 balance         of payments,                or
the    balance           of    trade      in high-technology                      goods.

          The challenge                that      the      United         States        must     face      is to turn            its
strength          in fundamental                 science       into         marketable            products         and
services          that        are    competitive            worldwide.                 This      is what         the

transfer              of technology             is all       about --but            we must carry                out    this

complex          transfer            process       without         impairing           our         capacity       to do
fundamental                 research         and development.

          To know whether                    innovative         ideas        that      have commercial
potential              actually        get      to market          requires           an adequate              framework            and
system          for      reporting.             As stated          in the       Stevenson-Wydler                   Technology
Innovation               Act       of 1980,      “Technology             and industrial                  innovation             are
central          to the           economic,       environmental                and social              well-being              of
citizens              of the United             States”       because          they        offer

          --           an improved             standard       of    living          in the          United       States,

          --           increased        public       and private-sector                       productivity,

          --           new industries             and employment                opportunities,

          --           improved        public       services,            and

          --           enhanced        U.S.      competitiveness                in the         world          market.

           If    we are            to assess      whether          the    technology                transfer
legislation                 can,     once fully           implemented,              help      achieve          these       things,
then      what         is    called      for     is a viable             system        for         collecting,
synthesizing,                  managing,         and reporting               information               on technology
transfer              activities.

           It   is     important               to note           that           our primary               assignment             was to
develop         and refine                criteria             and standards                    for       reporting             and to
demonstrate                the     viability              of     the           reporting          instrument              that     we
designed.             We are           pleased            to be able                   to report             that     we have
demonstrated                this         instrument              to be viable.                        The cooperation                we
received,            our     response             rate,          and the               preliminary             data       we describe
are       testimony          to       that       fact.           The Congress                   now has             the   only
comprehensive                data        base existing                     on federal                 technology            transfer
organizations                and operations.                          We owe our                success             to the       serious
commitment            of     federal             laboratory                scientists                 to technology               transfer.

           Although          our       initial            findings               are      based         upon        a preliminary

analysis         of     incomplete                data,          they           suggest         that,         nationally,            agency
and laboratory                   implementation                      of        the     Stevenson-Wydler                   Technology

Innovation            Act        of    1980       as amended                    by the       Federal            Technology
Transfer         Act        of     1986 leaves                 room for                improvement.                  Laboratories
seem to         require            more guidance                     from        agencies             regarding           the

implementation                   of    the amended act,                          direction              to    establish           ORTAS at
the   laboratory                 level        and        to    negotiate                CRDAs,          and    encouragement               to

consider         technology                  transfer            activities                important,                rewarding,           and

salient         in    the        consideration                   of       laboratory              staff        promotions            and

awards.          Further,              agencies               do not            appear       to       be encouraging

increased            participation                   by       laboratories                 in     FLC.          In sum,
preliminary             and incomplete                        data        do     suggest          that        agency        and

laboratory            implementation                      of     and       responsiveness                     to     provisions           of

the   amended act   need improvement.

      Mr.   Chairman,    this   concludes        my remarks.     I would   be happy   to
answer   any questions      you or the      Subcommittee       may have.

APPENDIX I                                                                      APPENDIX I

                        Sent    and Returned as of April     27,     1990

Organization                                                     Laboratory-level            Agency-level
                                                           No.     Sent      No.  Returned     Returned
     Agricultural             Research   Service                   54               49            Yes
     Forest         Service                                        12               11            Yes

    National    Institute     of Standards
      and Technology                                                 4               4            Yes
     National    Oceanic and Atmospheric
      Administration                                               22               22            Yes
     National    Telecommunications      and
      Information       Administration                               1               1            No

     Army                                                          42               41            No
     Air     Force                                                 14               14            Yes
     Navy                                                          19               14            Yes

    Conservation     6 Renewable            Energy                  1                1            Yes
    Defense Programs                                                4                4            Yes
    Energy Research                                                11               10            Yes
    Fossil  Energy                                                  2                2            No

  Health and Human Services
    Alcohol,  Drug Abuse and Mental
       Health Administration                                                                      Yes
    Centers for Disease Control                                     :                3            Yes
    Food and Drug Administration                                    6                6            Yes
    National  Institutes     of Health                             13               12            Yes

     Bureau of Land Management                                                                    Yes
     Bureau of Mines                                                                 ii           No
     Bureau of Reclamation                                                                        Yes
     U.S. Geological   Survey                                                        f            Yes
     Fish and Wildlife    Service                                                   13            Yes

APPENDIX I                                                       APPENDIX I
Organization                                       Laboratory-level                Agency-level
                                                 No. Sent      No. Returned          Returned
     Coast Guard                                       1              1                 No
     Federal Aviation Administration                                                    Yes
     Federal Highway Administration                                                     No
  Veterans Affairs
    Veterans Administration
       Medical Centers                               65              50                 Yes
  National   Aeronautic     and   Space
    Administration                                     9              9                 Yes
  Environmental    Protection      Agency             15             13                 Yes

Totals                                              338              302 (89.3%)        21 (78.8%)

                                                                                                    (886-t ‘E l: X e w

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