BOARD OF PUBLIC AND SCIENTIFIC AFFAIRS 
AMERICAN SOCIETY FOR MICROBIOLOGY 
1913 I Street, N.W. 
Washington, D. C. 20006 
Telephone: Code 202, 833-9680 
October 19, 1979 
Dr. Donald S. Fredrickson, Director 
National Institutes of Health 
Building 1, Room 124 
9000 Rockville Pike 
Bethesda, Maryland 20205 
Dear Dr. Fredrickson: 
The Committee on Genetic, Molecular, and Systematic Microbiology of the 
American Society for Microbiology Board of Public and Scientific Affairs 
recommends the following in regard to regulations of recombinant DNA 
investigations : 
1. Restrictions in the Guidelines should be revised downward as the evidence 
for lack of biohazards becomes apparent and justifies it. 
2. The Committee recommends the procedures for notification and approval of 
recombinant DNA work be streamlined. Workers should be able to modify 
protocols within the original intent, without the need for resubmission 
of MUAs. 
3. The Committee endorses the efforts by the NIH to extend the Guidelines to 
the private sector and has confidence in the way they are handling these 
matters. We recommend that the RAC be expanded to include members with 
expertise in industrial microbiology. 
4. We recommend that experiments in excess of 10 liters should be approved on 
a case by case basis. In this connection, we recommend that the members 
of panels have appropriate expertise by education, experience, and training 
to evaluate what is done. We believe the panel should include members with 
expertise in industrial microbiology and with familiarity in large scale 
containment operations. 
5. We remind you that ASM takes the position that training is another line of 
defense. Mechanisms should be established to ensure that investigators 
using recombinant DNA technology have adequate training on the principles 
and techniques of acceptable microbiological practice to achieve 
containment objectives. 
Sincerely 
hetj-x^n yj . iiaivuiouii, Ph . D . 
Chairman, Board of Public and 
Scientific Affairs 
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