may not have been taken into account. That is, the requirement that 
clones subject to the guidelines can be transferred to other labora- 
tories only after the recipient submits an approved MUA to the supplying 
laboratory provides a unique protection to investigators against theft 
or other unauthorized use of their clones. Such actions would constitute 
a clear violation of the guidelines. Such instances, as well as aacusa- 
tions and suspicions are bound to arise, and NIH will be drawn into many 
such disputes. While this requirement provides a potentially important 
protection for investigators, it also increases the danger that NIH 
will be more and more involved in regulatory, investigatory, and 
enforcement procedures. You may wish to consider the balance of these two 
elements in future decisions on exemptions. 
3. As one of the initiators of the proposal to lower K-12 containment, 
I am appalled at the interminable delays required before a recommenda- 
tion of the RAC can be put into effect. The procedures required by the 
December 1978 guidelines are cumbersome enough without an additional 
layer of public comment, n analysis, and justification added on. NIH 
and American biomedical scientists deserve better treatment and trust 
from their top health administrators. 
Sincerely 
Wallace PhrRowe, M.D. 
LVD, NIAID 
[5161 
