Dr. William J. Gartland 
- 2 - 
26 January 1982 
We recognize that there are undoubtedly investigators will 
feel that confonnity to non-mandatory "Guidelines” could be a burden. 
Even now, except in States and localities vdiich have e^^licit 
recorbinant DNA legislation, the private sector is not subject to the 
"Guidelines" unless federal s\ 5 :)port is received. Our own e^qjerienoe has 
been that investigators tend to be over-conservative in performing such 
research, using P2 containment vbere PI is allowed, for exaitple. In 
peurt, this has reflected a desire for the technical control that better 
containment represents more than concern about the possible hazards. 
It appears to us, however, that such "nonconformists" are in 
an extreme minority and that peer and other pressures will limit their 
propensity to follow less-than-adequate procedures. We already see 
evidence of this in relation to use of unregulated hazardous materials 
such as si^jertoxics and carcinogens vhere investigators following less 
than the norm for good laboratory practice are gently reminded by their 
colleagues of the need for inproved management. 
Hie "Guidelines" have also served a valuable function in 
establishing the concept of an Institutional Biosafety Conmittee (IBC) , 
and it seems most liJcely that institutions will enlarge on the role of 
the IBC to include oversight of research with pathogens vdiere 
reconfcinant DNA is not a factor. CXu: own IBC alreac^ has undertaken 
this to a limited extent. 
In sum, we believe that non-mandatory "Guidelines" are hi^ily 
desirable eis being a focal point for knowledge on the safe handling of 
reocnbinant DNA molecules, their hosts and vectors. We do not believe 
that mandatory "Guidelines" significantly iirprove conformity to safe 
practices. Vfe believe that investigators will comply voluntarily with 
the intent and content of non-mandatory "Guidelines" for the protection 
of themselves, their research, and the oonnunity. 
DKH:mgk 
[ 696 ] 
