Monsanto 
Monsanto Company 
800 N. Lindbargh Boulavard 
St. Louis. Missouri 63)86 
Phono: 014) 694-1000 
January 28, 1982 
Director, Office of Recombinant 
DNA Activities 
Building 31, Room 4A52 
National Institutes of Health 
Bethesda, Md. 20205 
Dear Sir: 
Monsanto Company appreciates the opportunity of responding to the 
Request for Connents on "Recombinant DNA Research: Proposed Revised 
Guidelines" published by the National Institutes of Health (NIH) in the 
Federal Register, Friday, December 4, 1981, p. 59368 and Monday, Decem- 
ber 7, 1981, p. 59734. 
Monsanto Company is a major international supplier of chemicals, 
plastics, textile fibers and other products. As have many companies, 
Monsanto Company has an active biotechnology research program in which 
recombinant DNA techniques are used. We voluntarily comply with the 
NIH Guidelines on research involving recombinant DNA molecules and an- 
ticipate that we will continue. An Institutional Biosafety Comnittee 
(IBC) reviews projects for conformance with the Guidelines. In addi- 
tion, a staff biosafety specialist provides consultation and oversight 
of all biotechnology programs. 
Monsanto Company has a tradition of commitment to safety, health 
and environmental protection. Implementation of that commitment in our 
research laboratories has required the development of standard proce- 
dures, committees, professional staff, training programs, special facili- 
ties and an emergency response mechanism. Special policies and proce- 
dures have been adopted for the handling of biological systems. 
Although the current and proposed approaches for the regulation of 
DNA experiments are acceptable to us, we believe a preferred approach 
would be to focus NIH expertise and experience on promoting the develop- 
ment of safety, health and environmental programs in all laboratories. 
Standard policies and procedures should be encouraged that clearly ad- 
dress the known hazards and utilize concensus standards relevant to the 
operations to be performed in each laboratory. 
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