Medical Research Conseil de recherches 
Council of Canada m6dicalos du Canada 
18 JanuaT 7 1982 
Dr. Bill Gartland 
Director, ORDA 
Building 31, Room 4A52 
National Institute of Health 
Bethesda MA 20205 
Dear Bill, 
Thank you for Inviting my comments on the material 
published In the Federal Register on December 4 and 7 concerning 
the upcoming meeting of the RAC. 
I see 3 major Issues In any country's approach to 
guidelines: 
The scientific validity of the matching of 
proposed containment for various experiments 
to the perceived risks; 
the procedures used by an Institution, be It 
federal or academic, to enforce the appropriate 
containment standards; 
the legal effects of documents relating to 
safety. 
All these three Issues are central to the proposed 
revisions. 
1. The scientific validity of the Guidelines 
I support the thrust toward the principle that the 
containment required for recombinant DNA experiments shall be that 
determined by the most hazardous of the components of the system, 
with Pl-HVl basically the lowest level. This Is generally %/here 
the Canadian Guidelines have been since mid 1980 (copy enclosed). 
Ottawa. Canada 
K1A0W9 
I have some comments on the t%x> proposals : 
