Dr. Donald Fredrickson 
Page 2 
May 8, 1981 
Thus, we cannot make any statements about the safety of III-O experiments 
which would justify exempting them from the Guidelines. Thus, we cannot 
justify allowing work with genes coding for toxins in the absence of 
supporting risk assessment work. 
Finally, the proposal by Drs. Baltimore and Campbell would continue an 
ill-advised trend. Over the past few years the Guidelines have been 
relentlessly watered-down, with responsibility for overseeing r-DNA work 
transferred from NIH to institutional biohazard committees. Most, if not 
virtually all, of these committees are woefully unprepared to handle these 
responsibilities. I speak from my 3 years experience on one of the better 
of them. IBCs do not have sufficient staff time (via the BSD or otherwise) 
to assure that what is going on in the laboratories actually reflects 
what is written in the Guidelines^ for example, as you well know, NIH 
has only recently begun to consider a program to assess the structure and 
performances of IBCs. However, the IBCs have served as a useful screening 
device, and a forum for airing of local concerns, at minimal cost in either 
dollars or time. Thus, NIH should continue to require their existence and 
adequate functioning. 
Thank you for your consideration of my views. 
Associate Professor 
PLB:ec 
cc: Hon. Richard Schweiker, Secretary, U.S. Dept, of Health and Human 
Services, Washington DC 20014 
Sen. Orrin Hatch, Chair, Convnittee on Labor and Human Resources, U.S. 
Senate, Washington DC 20510 
Sen. Edward Kennedy, Conmittee on Labor and Human Resources, U.S. 
Senate, Washington DC 20510 
Rep. Doug Walgren, Chair, Subc. on Science, Research and Technology, 
U.S. House of Rep. Washington, DC 20515 
Rep. John Dingell, Chair, Comittee on Energy and Commerce, U.S. 
House of Rep. Washington DC 20515 
[ 595 ] 
