STANFORD UNIVERSITY MEDICAL CENTER 
STANFORD, CALIFORNIA 94305 
DEPARTMENT OF BIOCHEMISTRY 
Stanfou) Univehsitv Schooi. of Medicine 
Area Code 415 
497-6161 
January 22, 1982 
Dr. William J. Gartland 
Department of Health and Huoian Services 
National Institutes of Health 
Bethesda , HD 20205 
Dear Dr. Gartland, 
I am writing in support of the RAC proposal to revise the NIH Guidelines 
for Recombinant DNA Research as set forth in the Federal Register of December 
4, 1981. 
I believe that the Guidelines for Recombinant DNA research are now 
dispensible. Based on the substantial amount of experience and 
ezperiaientation with the recombinant DNA methodology during the last six 
years, there is widespread agreement that the risks that were once thought to 
be so plausible are actually remote or possibly nonexistent. If that 
Judgement is indeed correct, and I know of no evidence to indicate otherwise, 
then it seems wasteful of effort and money, even counter-productive, to 
maintain the elaborate procedures and organizations that were setup to guard 
against the hypothetical threats. It has been my long-held view that the most 
beneficial feature of the Guidelines was their educational role; they 
highlighted the kind of concerns that were voiced and provided recommendations 
for workers in the field as to how safety considerations should be 
incorporated into their experimental designs and procedures. For that puirpose 
referring to the revised Guidelines as a Guide (or Code) for Good Practice 
seems appropriate. 
There is one minor point in the wording of the RAC proposal with which I 
differ. Eaiphasizing that the new recommendations are 'voluntary' places an 
unintended and unnecessary psychological focus on the change. I suspect that 
if the voluntary nature of the recommendations is emphasized, many will take 
that as an invitation to ignore them completely; after all who cares. But if 
the revised version makes strong recoanendations and accompanying 
justifications for how such experiments should be carried out, there is a 
stronger llklihood that people would accept the recommendations as being 
reasonable. I prefer the approach the CDC uses, namely, to advise scientists 
of the concerns about certain organisms and make recommendations for how to 
work with various types of microbial pathogens and viruses. Voluntarism, while 
i^ilicit, is deeoiphasized in favor of urging cooipliance. 
I am strongly in favor of maintaining RAC but not necessarily ORDA except 
in so far as it serves a small staff function for RAC. RAC could well serve 
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