HARVARD UNIVERSITY 
DEPARTMENT OF CHEMISTRY 
12 Oxford Street 
Cambridge, Massachusetts 02138 
USA. 
January 28, 1982 
William Gartland, Ph.D. 
Director 
Office of Recombinant DMA Activities 
National Institutes of Health 
Building 31, 4A52 
Bethesda, Maryland 20205 
Dear Dr, Gartland: 
The Institutional Biosafety Committee of Harvard University Faculty 
of Arts and Sciences met to discuss at some length the proposed 
revisions to the recombinant DNA guidelines. Although not quite 
unanimous, the majority of members voiced reservations concerning 
some of the changes being proposed. Of utmost concern was the speed 
with which the relaxation is being considered. We recognize the 
need for simplification and some relaxation of the guidelines and 
encourage their continued thoughtful evolution, as has occurred since 
1978. 
Aside from the above concerns, such significant changes will certainly 
present problems in communities which have implemented regulations 
governing recombinant DNA work. Most communities with such regula- 
tions have adopted existing NIH Guidelines as a framework for their 
own regulation. Consistency has been obtained, in large part, because 
local communities believe that the NIH has not taken lightly its 
responsibility with respect to the development and promulgation of 
their guidelines. In the absence of regulations which have been written 
with the advice of the scientific community and the public at large, 
we fear that the benefits of this new technology will not be forthcoming. 
We also feel that the concerns of the public regarding this research 
should not be underestimated at this time. 
Finally it is this committees concern, that should these changes be 
adopted and local regulations not be altered, recombinant DNA research 
and development activities in Massachusetts would be conducted at a 
definite disadvantage compared to other regions. We urge a more careful 
relaxation of the guidelines than has been proposed. ^ 
William N. Lipscomb, Ph.D. 
Chairman - Committee on the Regulation 
of Hazardous Biological - Faculty of 
Arts and Sciences 
[ 710 ] 
