Dr. William J. Gartland - January 12, 1982 
Page 2 
It is now time to take as bold a move as did those scientists at the 
Asilcmar meeting. That move is to call a moratorium on the bureaucracy of 
recombinant DNA technology. The IBC's have over the last few years carried 
out their responsibilities in a conscientious and sincere manner but the 
time has cone to dissolve these anachronisms. Believe me this statement is 
not easy to make after having served for two years as Chaiiman of the IBC at 
the University of Rochester and responsible for establishing a small bureauc- 
racy to deal with recombinant DNA experiments. However, as most recombinant 
DNA experiments fall into the exempt category, the function of the IBC has 
become less meaningful. While some would embrace the proposal submitted by 
Dr. Susan Gottesman (Federal Register, December 7, 1981), I feel there is no 
need for retention of IBC's at local institutions. 
If the RAC proposal of 12-4-81 were to be adopted, it is not clear to me what 
would be the fate of the NIH office of Recombinant DNA Activities. They 
have, over the years, with the help of RAC been so helpful in providing 
information on containment and good laboratory practice, that I would like 
to see them remain as an informational service providing up to date reviews 
and news that is normally published in the Recombinant DNA Technical Bulletin. 
The guidelines should be changed to a voluntary code of standard practice. 
This code should be updated to reflect new discoveries by individuals in the 
field. It should not continue to be mandatory for institutions receiving 
NIH funding. The original purpose of the guidelines was to establish the 
potential risk of the experiments, not to distinguish between research under 
NIH funding or funded by a private sector. The past seven years have shown 
us that individual researchers are conscientious and have not applied 
recombinant DNA technology to make harmful microorganisms or products. If 
this were the aim of some malign individuals, retention of the IBC or man- 
datory compliance to the guidelines would not deter these individuals. It 
is time to take a bold step and remove the bureaucracy that has plagued 
recombinant DNA research. I enthusiastically endorse the RAC proposal and 
believe the revisions are necessary and timely. 
Sincerely, 
/pv 
cc: R. J. Erickson 
K. H. Meyer 
W. Himmelsbach 
F. E. Young 
G. A. Wilson, Ph.D 
[ 656 ] 
