4. ) In general I support your concept of biological containment. 
It may be helpful to provide a clear assessment of the efficacy of 
biological containment in view of its great implementation. Although it 
is asthenic and nice in laboratory terms it is not clear whether this 
type of containment is really effective or whether K12 would be suf- 
ficiently inactivated in the environment. Thus, as Chairman of our 
Biohazard Committee I would particularly appreciate a critique of the 
efficacy of biological containment. 
5. ) Because the State of New York and possibly other states will 
be enacting legislation it is important to look at the guidelines from a 
standpoint of their implementation as law. I am enclosing for your 
reference a copy of the New York State bill. You will note that there 
are requirements for compliance with the NIH guidelines, registration of 
projects and responsibilities for education. In order to effect this 
compliance with maximal efficiency it will be important to have a high 
degree of responsiveness by the Recombinant DNA Committee. I applaud 
the increased delegation to the Institutional Biosafety Committee and in 
fact raised this strongly in my testimony at Rogers subcommittee a few 
years ago. Because of this increased responsibility on the part of the 
local biosafety committee it is imperative that NIH notify the chairman 
of the biosafety committee as well as "the institution" during its 
official feedback. It was mentioned repeatedly that NIH would notify 
the institutions, however it was not clarified that the Chairman of the 
Biosafety Committee would be notified. In order to have this individual 
fully informed, such notification is imperative in my opinion. It will 
also be imperative to have NIH provide a statement that it has certified 
the institution and finds that it is in compliance rather than merely 
noting this on the bottom of an NIH grant. Such documentation would be 
most helpful for the University. This is particularly important if 
liabilities are to accrue to the institution. While it is clear that 
NIH has no intention of instituting fines or other penalties beyond the 
grant process, state regulations may not follow the same route. 
6. ) It is important to give careful consideration to the registration 
of students who are involved in recombinant DNA projects. It would be 
most helpful if all of the students could be listed regardless of NIH 
training grant support. This would enable one central listing to serve 
for whatever training grant or research grant the student is supported 
on. I've enclosed for your reference in this matter, the information 
that I received from NIH in regards to my query on training grants. 
Possibly some of this ought to be incorporated into the guidelines. 
7. ) The section on a rodent and insect control is vague. I wish 
that this would be spelled out more clearly so that I would know as an 
Institutional Biosafety Committee Chairman how to access this. Possibly 
this will be forthcoming in some of the other appendices and amplified 
in these guidelines. 
8. ) I believe that it is imprudent to publish the list of exchanges 
just with the emphasis on the JC. coli model system. I have two objections 
to this: First, there is insufficient documentation and review of this 
contention in the literature. While I am trying to do this myself for a 
review to be submitted to the Annual Review of Microbiology, I believe 
[A-151] 
