STANFORD UNIVERSITY 
STANFORD, CAUFORNIA 94305-2493 
DEPARTMENT OF BIOLOGICAL SQENCES 
January 19, 1982 
Dr. William J. Gartland, Jr., Ph.D. 
Director, Office of Recombinant DNA Activities 
Building 31, Room 4A32 
National Institutes of Health 
Bethesda, MD 20205 
Dear Dr. Gartland: 
I have examined and compared the two current proposals for 
revising current NIH Guidelines (Fed. Reg. 12/4/81 and 12/7/81). 
The Gottesman proposal represents a marked improvement over 
the current Guidelines, in liberalizing containment levels and 
reviev procedures. But it does not go far enough. I am convinced 
that the time is long overdue for the Guidelines to be made entirely 
nonmandatory. 
In the absence of any demonstrated hazard, I see no Justifica- 
tion for continuing to mandate the formal reviev procedures stipulated 
by the present Guidelines on the revisions proposed by Dr. Gottesman. 
I therefore strongly support the original RAC proposal. 
Sincerely yours. 
David D. Perkins 
Professor of Biology 
DDP/cml 
( 673 ) 
I 
