CITY OF CAMBRIDGE 
DEPARTMENT OF HEALTH. HOSPITAL AND WELFARE 
1493 CAMBRIDGE STREET CAMBRIDGE. MASSACHUSETTS 02139 
Telephone 354-2020 
January 21 , 1982 
Director, ORDA 
Building 31, Room 4A52 
National Institutes of Health 
Bethesda, MD 20205 
Re: Proposed changes in Guidelines 
Federal Register of 12/4/81 
Dear Sirs: 
The Cambridge Biohazards Committee was established by 
local city ordinance in 1976-77, and has since that time 
reviewed recombinant DNA use in Cambridge, Massachusetts. 
Within the last two years we have reviewed in detail every 
change in the NIH Guidelines, reviewed in detail (and helped 
to revise) the local ordinance governing recombinant DNA use 
in this city, listened to extensive testimony from experts on 
large scale and small scale recombinant DNA use, inspected 
local laboratories using recombinant DNA, conducted a public 
hearing on recombinant DNA use, and testified before our city 
councillors on this issue. We have also had many extensive 
and detailed discussions with the Biological Safety officers 
of Harvard and MIT. Since we are local citizens not person- 
ally involved in recombinant DNA research, we think our 
coiiunents on the recently proposed Guidelines can provide an 
unusual and useful perspective to the Federal Government as 
it considers these proposed revisions. Each of us has long 
experience in local civic affairs. 
We recognize the need to simplify the Guidelines, par- 
ticularly the specification of containment levels. We do 
not, however, think it is wise or necessary to abolish In- 
stitutional Biosafety Committees. We believe such committees 
provide a useful restraint on careless or overconfident 
researchers and an essential reassurance to local communities. 
The selection of appropriate containment levels for certain 
uses of recombinant DNA will remain complex, even with simpli- 
fied Guidelines. Complex decisions are often improved by 
consultation with other thoughtful people. Secondly, whenever 
individuals use potential pathogens, or other potentially 
harmful materials for personal gain or financial reward, a 
conflict of interest can arise. In this situation, it is 
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