THE INSTITUTE FOR CANCER RESEARCH 
TTOl AVENUE 
FOX CHASE • PHI I.ADE1.PHIA, PENNSYLVANIA 18111 
(SIB) OAS-IOOO' CABLE ADSUBSSi CAHBZABCB 
January 8, 1982 
Dr. William J. Gartland, Jr. 
Director 
Office of Recombinant DNA Activities 
National Institutes of Health 
Building 31, Room 4A52 
Bethesda, MD 20205 
Dear Dr. Gartland: 
I am writing to comment from the point of view of an IBC chairman on the 
relative merits of the two proposals to revise the DNA Guidelines described In 
the Federal Register of December 4 and 7, 1981, and summarized In your memo- 
randum of December 18, 1981. I should like to point out some problems that 
might arise In attempting to Implement the "Gottesman proposal". 
This Institute had had a staff committee on laboratory safety prior to the 
origin of concerns over recombinant DNA. Its Influence with the staff and with 
the director stemmed from Intellectual agreement that certain aspects of labo- 
• ratory research Involved real hazards and that our responsibilities to our col- 
leagues or to the public required that safe handling practices be explored and 
developed and that appropriate safety guidelines be taught and observed. With 
the advent of the NIH Guidelines, this committee was modified, expanded, and 
Institutionalized In order to bring It Into compliance with what had become 
de facto federal regulations. This procedure found legitimacy and acceptance 
among our scientific colleagues only because there was at that time credible 
scientific concern over the safety of recombinant DNA research. All investi- 
gators did not give equal weight to these concerns but the views of those who 
counseled caution were acceded to. Staff cooperation with the IBC was excel- 
lent and outside members were glad to participate In our deliberations. 
The following years saw a considerable expansion of recombinant DNA re- 
search at this Institution, as at others, with concomitant Increases In knowl- 
edge of both genetics and the process of Infection that made It Increasingly 
clear that the dangers of recombinant DNA research had been substantially 
overestimated. During this period, progressively more liberal guidelines came 
Into use and the work and responsibility of the IBC was accordingly diminished. 
Most importantly, the Intellectual basis for the IBC's authority had been 
correspondingly dissipated. As a result, respect for the IBC's function has 
decreased and colleagues are no longer as willing to serve as IBC members. As 
chairman, I now find It embarrassing to have to make demands on the time of our 
outside members (public health officials) to deal with matters that are essen- 
tially legalistic, rather than biological or medical. 
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