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February 1, 1982 
Dr. William J. Garcland 
Director 
Office of Recombinant DNA Activities 
Building 31, Room 4A52 
National Institutes of Health 
Bethesda, Maryland 20205 
Re: Proposals to modify NIH's guidelines for research involving 
recombinant DNA molecules, A6 JF.R. 59368 (December 4, 1981) 
and 46 F.R. 59734 (December 7, 1981) 
Dear Dr. Gartland: 
The comments set out below are submitted on behalf of the Board of 
Directors of the Industrial Biotechnology Association, Inc. (IBA). IBA is 
an association of industrial organizations actively involved in biotechnology 
programs. The association's purposes include promotion of commercial bio- 
technology and enhancement of its contributions to the public welfare, as 
well as cooperation with governmental agencies exercising responsibilities 
in the area of biotechnology. A list of IBA members as of February 1, 1982 
is included with this letter. 
We believe that the Deconber 4 proposal by the RAC and the December 7 
proposal by Dr. Susan Gottesman are each persuasive in some respects. Their 
best features should be combined to replace the present guidelines with a 
modernized version that will encourage variety and innovation to a greater 
extent, while retaining the confidence of both the scientific community and 
the general public. 
The thrust of IBA's combined proposal is two-fold. First, we agree with 
the scientific Judgments expressed in the RAC proposal to the effect that to- 
day's specific containment requirements are generally unduly conservative. 
Since the scientific community's self-initiated pause in the mid-1970's and 
formulation of the first version of the guidelines in 1976, much new recom- 
binant DNA work has been performed in university and industrial laboratories 
6110 Executive Boulevard, Rockville, MD 20852 (301) 984-9599 
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