( i{ '( ); 'Ml I M 'll, ll lit. 
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Genentech, Inc. 
( ii 'I U 'Mi ( '( ;} 1 , ll x:. 
460 Point San Bruno Boulevard 
South San Francisco, CA 94080 
(415)952-0123 
TWX: 9103717168 
February 1, 1982 
Dr. William Gartland 
Director. Office of Recombinant 
DNA Activities 
Building 31 » Room 4A52 
National Institutes of Health 
Bethesda. Maryland 20205 
Re: Notice of proposed revisions of the NIH Guidelines for Research 
Involving Recombinant DNA Molecules -Fed. Reg. Vol. 46, No. 233, 
p. 59368, December 4, 1981 and Fed. Reg. Vol. 46, No. 234, p. 59734, 
December 7, 1981 
Dear Mr. Gartland: 
We are pleased to submit, our comments on the proposed revisions 
of the NIH Guidelines published in the December 4 and December 7, 1981 
Issues of the Federal Register. Our detailed comments on specific sections 
of the proposals follow. 
First, we would like to support the continuing evolution of the 
recombinant DNA guidelines as our body of knowledge concerning this 
technology Increases. Both proposals are significant steps forward in 
this regard. We believe the guidelines have served and should continue to 
serve a useful purpose in assisting those Involved with this technology 
to make Informed judgements. As the guidelines have developed, there 
has been a healthy dialogue at the national level between people with 
differing points of view and therefor an open and realistic assessment of 
the potential risks of recombinant DNA technology has developed. The 
alternative to the attentiveness of the NIH could well be a patchwork 
of local and state regulations which might Impede our national progress 
and do nothing to assure additional safety. 
[ 750 ] 
