Mr. F. Peter Libassi 
- 2 - 
September 14, 1978 
Retention of the section which will permit all institutions to register 
Recombinant DNA Research with NIH should allay industry's concern regarding 
disclosure of proprietary and patentable information, since one governmental 
agency only would receive confidential information. As an additional benefit, 
retention of this section will provide the private sector an opportunity to 
demonstrate their social responsibility and enhance public credibility. 
Another area of concern to us at the State level is that of major spills or 
transportation accidents of etiologic agents. As referred to on Page 33067 of the 
Federal Register Report, a team of experts from NIH and CDC could be formed to 
respond to emergencies of this nature. However, for a prompt and adequate 
response, it is essential that such a team(s) be formed and the names and telephone 
numbers of the members of such team(s) be published in the Guidelines for easy 
access in an emergency. Furthermore, the Guidelines should stipulate that some 
State Agency, such as the Health Department, be notified immediately in case of 
such accidents. 
Finally, we propose that the following wording "and responsible State 
Agencies" be added to part IV-B-3-a-(4) so that it will read as follows: 
Provide timely notice to local institutions and responsible State Agencies 
when protocols, including modifications to on-going projects, do not conform 
to the standards in the NIH Guidelines. 
Thank you for the opportunity to present these statements at the public 
hearing. 
Sincerely yours, 
Dhun B. Patel, Ph.D. 
Environmental Scientist I 
Biological Services 
DBP:ds/st5-01 
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