AttacJment IV - Page 2 
FXtrthT R»coein«ndatlon« 
Wa tha undaraignad agraa vlth tha gcnaral thruat of tba 
racoantandations of tha Working Group on Racooblnant DMA Culdalinaa. 
In particular, wa aupport tha racomnendatlon that thoaa axperlnanta, 
for which contalnatant guldallnaa ara ratalnad, ara to confora to 
good laboratory practlca aa daacrlbad In tha CX>C and APHIS Quarantlna 
rulaa. Tha racoonandatlon that abollahaa the category of prohibited 
axparlnanta la aclentlflcally aound In tha light of current knowledge. 
The content of the auggaated containment guldellnea followa from the 
overall conclualon that raiaarch with recombinant DMA Impoaaa no 
Bora rlak than any other biological raaearc^. The background paper 
aaply docunanta thla point. 
Therefore, wa find no reason to retain tha Administrative Gulda- 
IXnas (Section ZV) . Tha spirit of tha Baltlmora>Campbell resolution 
and, as titled. Its major purpose, was to convert tha NIH Regulations 
Into Guidelines. Retaining pages of bureaucratic regulations for 
what la now perceived to require only limited oversight Is a waste of 
time and effort, will not add to safety In any way, and will be dis- 
dained as bureaucratic capriciousness. 
Edward A. Adclberg 
Kenneth I. Bams 
Herman W. Lewis 
Sue A. Tolln 
Norton D. Binder 
Given the recommendations for tha containment guidelines and 
what would be proper for the adnlni strati ve guidelines, we the under- 
signed conclude that special guidelines for recombinant DNA are 
totally unnecessary. Therefore, we further recommend that as of 
June 23, 19B2 the NIH Guidelines cease to exist. 
The arguments for their retention are primarily social and 
political/ they do not have a scientific base (see Background Paper) . 
Zt seems right, at this tine, to disavow such arguments and base our 
conclusions solely on the scientific Issues. RAC should reconsnend 
the abolition of the Guidelines. Zn doing so, It should prepare a 
strong statement of Its rationale to be published In Science and 
Nature as well as the Tederal Register. This statement should also 
contadn as recocsnendatlon the containment guidelines for recombinant 
DMA experisients developed by the Working Group. Prepared as the cul- 
mination of years of consideration and analysis, such a statement 
would serve to inform both the scientific co mm unity and the public of 
the safeby of research with racooblnant DMA. 
Edward A. Adelberg 
Morton 0. Binder 
(2411 
