Program Ethics and 
Federal Regulations 
Colorado State University 
Fort Collins, Colorado 
80523 
Office of the Executive Secretary 
303/491-7162 
February 1, 1982 
William J. Gartland, Jr., Director 
Office of Recombinant DNA Activities 
National Institutes of Health 
Building 31 , Room 4A52 
Bethesda, Maryland 20205 
Dear Dr. Gartland: 
As executive secretary of the CSU Biohazard Committee, I have canvassed 
the scientific community regarding the two proposals for a major revision 
of the NIH Guidelines for Research Involving Recombinant DNA Molecules. 
One of our scientists strongly favors the revision in the Federal Register 
of December 4, 1981. He can do this with confidence because of the high 
standards of biosafety set at Colorado State University. From an ethical 
standpoint, however, I feel that this set of standards cannot be assumed 
to exist at all institutions. Bernard Rollin, Ph.D., the CSU Director 
of Bioethical Planning is also concerned with a progressive decline in 
biosafety standards that can result from the absence of federal regulations. 
Dr. Roll in's statement is as follows: while it certainly makes sense to 
simplify requirements and eliminate bureaucracy, biosafety does not seem 
to be the best area in which to do this. Innocent persons are at risk 
and deserve, at the very least, the sort of safeguards which have hitherto 
been extant. The cost to researchers is a mild annoyance at worst; the 
benefit is some degree of extra care in using hazardous material and 
increased awareness of the social and ethical implications of science. 
To make guidelines voluntary is essentially to render them meaningless, 
as the history of the NIH Guidelines re laboratory animals has clearly 
shown. The December 7 proposal seems a reasonable compromise. 
I concur completely with Dr. 0 r.inn'c ctatomont 
David H. Neil, B.V.Sc., MRCVS 
Executive Secretary 
DHN:cr 
Committee on Humarr Research • Animal Care Committee • Biohazard Committee 
Painter Center for Laboratory Animals 
[764] 
