-3- 
Sectlon III.C.2. 
Section IV. D. 2. 
Experiments Involving Formation of Recombinant DNA 
Molecules Containing No More than Two-Thirds of 
the Genome of Any Eukaryotic Virus 
Comment ; We question the selection of a certain size 
fraction of the viral genome as the only criteria for 
establishing containment levels. We recommend that 
"evidence that the genome is totally and irreversibly 
defective" be used as an alternate criteria as is done 
in sections III. B. 2. a and III.B.2.b. Simlarly Sections 
III. B. 2. a and III.B.2.b should include "no more than 
two-thirds of the genome of any eukaryotic virus" as 
an alternate criteria for reducing the containment level 
in these classifications of experiments. 
Membership and Procedures of the IBC 
The Guidelines currently specify the membership of the 
IBC in terms of the number of non-af filiated members 
required, the number of nondoctoral members, etc. 
We believe that the Guidelines should be revised to 
state only the expertise that is required and that this 
may be accomplished with members selected from within 
and/or outside of the Institution. 
Section IV. E. 2. Recombinant Advisory Committee 
Because many commercial corporations have committed to 
comply with the Guidelines on a voluntary basis as 
evidenced by requests for exemptions to the 10 liter 
limit published in the Federal Register, we believe it 
is Important that industry's viewpoint be represented 
on the RAC and suggest that the statement "Representatives 
from industry may serve as non-voting members" be added. 
Again, we thank you for the opportunity to comment on the 
proposed revisions to the NIH guidelines. 
Sincerely 
Dr. Michael Ross 
Director, Protein Chemistry 
MR:bs 
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