STANFORD UNIVERSITY 
STANFORD. CALIFORNIA 94303 
partment of biological sciences 
September 22, 1980 
Dr. William Gartland, Chief 
Office of Recombinant DNA Activities 
National Institute of Health 
Building 31, Room 4A-52 
Bethesda, Maryland 20205 
Dear Dr. Gartland: 
I fully support in principle the proposals of Dr. Maxine Singer, as 
published in Federal Register 45, No. 164 (August 21, 1980), pages 
55926-55928. Specifically, submission of MUA’s to ORDA should no 
longer be required for grant proposals or ongoing grant support. 
Local IBC’s should be authorized to review and approve experiments 
covered by the Guidelines, while ORDA would function mainly to 
interpret and clarify the Guidelines. 
The present complex system of review on both local and Federal levels 
is no longer necessary. It is wasteful of time, effort, and money. 
It is, in fact, counterproductive because bureaucratic requirements 
seen by investigators to be clearly unnecessary lead to disrespect 
for regulations that should be respected. Institutional Biosafety 
Committees should, in my opinion, be fully capable of monitoring 
laboratory practices and containment levels specified by the 
Guidelines. 
While I have not checked all minor details of the wording changes, 
the main changes proposed by Dr. Singer seem to me to be clearly 
justified by current knowledge. I expect that the time is not far 
off when federally mandated bureaucratic procedures related to 
Recombinant DNA can be completely eliminated. 
Sincerely yours. 
David D. Perkins 
Professor of Biology 
DDPsgm 
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