Slate of Nero Jersey 
DEPARTMENT OP HEALTH 
DIVISION OF COMMUNITY HEALTH SERVICES 
CONSUMER HEALTH SERVICES 
JOANNE E. FINLEY. M.D.. M.P.H. 1911 PRINCETON AVENUE 
COMMISSIONER TRENTON. N.J. 06648 
September 14, 1978 
Mr. F. Peter Libassi 
General Counsel 
Department of Health, Education and Welfare 
National Institute of Health 
Building No. 31, Room 2B50 
Bethesda, MD 20014 
Dear Mr. Libassi: 
On behalf of the Department of Health and the Public Health Council of the 
State of New Jersey, we are in full support of the efforts of the National Institutes 
of Health, the scientific community and public interest groups which have enabled 
the development of Guidelines on Recombinant DNA Research. 
In the State of New Jersey we are concerned about the conduct of research 
at all institutions which have on-going projects or are planning projects involving 
Recombinant DNA. In particular, we are concerned about research at those 
institutions which do not receive NIH funds and are not subject to the NIH 
Guidelines. 
Therefore, we strongly urge you to retain in the final version, Sections IV-C- 
2, IV-C-3, and IV-C-4 of the NIH Revised Guidelines as published in the Federal 
Register, Vol. 43, No. 146, Friday, July 28, 1978. These sections are titled 
"Voluntary Registration and Certification", "Disclosure of Information", and 
"Patentable Materials". 
In essence, by retaining these sections, any institution which is not covered 
by the Guidelines will be permitted to register their Recombinant DNA Research 
Projects with NIH, and can request certification of proposed host-vector systems 
by NIH. The registrants will in turn be required to abide by the physical and 
biological containment standards of the NIH Guidelines. 
As you know, review of project proposals and certification of host-vector 
systems requires enormous resources both in terms of scientific personnel and 
finances. Thus, it would place a heavy burden on state governments if NIH decides 
not to retain the above cited sections of the NIH revised Guidelines. 
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