THE ROCKEFELLER UNIVERSITY 
12 30 YORK AVENUE - NEW YORK. NEW YORK 100 21 
ooli CNA into it represent a class of the most benign but useful types of 
experiments. The principle of the containment label matching the most poten- 
tially hazardous ccrponent should apply here as well as in the rest of the 
Guidelines. No potential danger, no special containment. The absence of this 
null category has in the past clouded the public discussions. Despite the 
graded series of containment levels, recent) inant DNA research was visualized 
as one thing. Thus if hazard was assumed to be associated with any of its 
parts, e.g. forbidden experiments, it was all hazardous. 
The new duties of the I.B.C. will make the Guidelines a bit more like 
guidelines and less like rules. As the Guidelines note, it can't anticipate 
every experiment and neither can any investigator. Basic research moves in 
erratic directions because its data base is continuously changing. New 
information , ideas and techniques suddenly appear. Hence experimental approaches 
are modified, dropped and new ones initiated. A distantly approved MUA tends 
to codify one approach. Were the Guidelines really guidelines most amended 
MUA's wouldn't be needed; new approaches generally fall into the category pre- 
viously approved. Under the new system it would require only a meeting of the 
I.B.C. to oertify moving in the newly logical direction. 
However this authority for the I.B.C. must be viewed as a mixed blessing. 
As with any local authority, extraneous considerations may enter the decisions. 
Given a strong I.B.C. sane colleagues will have authority over the research 
of other colleagues and opportunities for mischief may exist. It would be 
helpful if a review- appeal mechanism by the ORDA and RAC were written into the 
Guidelines. 
In sun, all of those involved in the preparation of the PRG should be 
ccftmended for their attention to principle and detail. I find little to fault 
in the technical aspects and find that the procedural aspects are not only 
generally appropriate but are also much less ambiguous that those of the current 
guidelines. 
I strongly reoermend that the PRG be approved as soon as possible so that 
the work may proceed with as little hassle as possible. 
Sincerely yours 
Norton D. Zinder 
NDZ :bc 
[A-81] 
