404.842.2«t« 
THC UNIVERSITY OF GEORGIA 
OC^AMTMKMT Or CNTOMOLOOY 
ATMCMS. aCOMIA »0«Oa 
U.S.A. 
January 28, 1982 
Or. William J. Gartland, Jr., Director 
Office of Recombinant DNA Activities 
National Institute of Health 
Bethesda, MO 20205 
Dear Dr. Gartland: 
The University of Georgia Biosafety Coinnlttee would like to 
offer the following coflments on the proposed changes In the NIH 
Guidelines for research Involving recombinant DNA molecules. We 
believe the RAC proposal (Federal Register 12/4/81) goes too far In 
removing certain restrictions, and that the Gottesman proposal 
(Federal Register 12/7/81) Is more restrictive than necessary. Of 
the two proposals, we support the RAC proposal, providing that the 
following additions are made: 
1. retain the local Institutional Biosafety Conwlttee; 
2. require IBC approval prior to Initiating any experiments 
Involving the transfer of drug resistance or toxin genes 
to bacterial species In which they are not found In nature 
or the deliberate release to the environment of any 
organism containing recombinant DNA molecules; 
3. require that the IBC notify the NIH of any IBC-approved 
project of the type described In #2 above. 
Many Institutions having a Biosafety Comnittee will retain It to 
evaluate experiments Involving other types of hazards, I.e. human 
pathogens, oncogenic viruses, etc. Institutions, through their 
Biosafety Committee, will want to be Informed about experiments being 
carried out within their Jurisdiction that Involve transfer of drug 
resistance or toxin genes, and especially the deliberate release of 
novel organisms. If for no other reason than to avoid the embarrasment 
of Ignorance about such experiments should the public become alarmed by 
news of the initiation of one of these projects. 
Our rationale for notifying the NIH Is to Insure that the RAC will 
always know what types of experiments related to transfer of drug 
resistance or toxin genes or the release of organisms are being carried 
out. It Is conceivable that at some future time, the RAC may decide that 
a particular experiment poses a significant hazard and should be terminated. 
Very truly yours. 
AOLiljs 
Arden 0. Lea, Chairman 
University of Georgia 
Biosafety Coninittee 
