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that such recommendations are tentative and will be modified 
as new information becomes available. This would permit 
investigators to explore the feasibility of such experiments 
and lay the groundwork for settling on the final containment 
requirements of such experiments. As matters now stand the 
absence of a policy is tantamount to a ban on such experiments. 
6. There are also several comments and concerns about 
the procedures set forth in PRG-NIH. 
a) I support enthusiastically the change that permits 
local IBC's to approve proposals and the investigator to 
initiate the experiments after obtaining such approval. 
The previous procedures were cumbersome, time-consuming 
and unnecessary. In my view the greatest risk to non- 
compliance with The Guidelines is for investigators 
to be confronted with an unresponsive, time-wasting 
bureaucracy. I have been impressed with how efficiently 
and unobtrusively (for the institutions and investigators) 
the procedures for safe-handing of radio-isotopes are 
administered. Hopefully surveillance of recombinant DNA 
research can be made as routine as the procedures used for 
experimentation with radio isotopes. 
b) As a member of an IBC I am particularly sensitive to 
the workload imposed on that body by the Recombinant 
DNA Guidelines. I am sure you are cognizant of the 
monetary costs in faculty and staff time needed to 
enforce them. Presumably, this gets charged to indirect 
costs, thereby making the costs of research to all granting 
agencies still higher. I hesitate to inquire what the 
costs of IBC time have been to Stanford during the past 
year. I suspect that these costs together with those attributable to 
your interminable involvement in these matters introduces a 
further and substantial drain on an already shrinking 
NIH research budget. 
c) I note that the PRG-NIH requires that all, not just 
NIH funded, recombinant DNA research at institutions 
receiving NIH support must comply with The Guidelines. 
But the instructions for how non-NIH funded research is 
to be reviewed, reported, monitored etc. are not clear 
enough. My deductions from reading Section IV A-D in 
Appendix C (particularly paragraphs IV D 1-10) are that 
a non-NIH funded project must be reviewed, approved and 
reported as is done for NIH-supported research. Since 
formal approval is no longer needed prior to initiating 
the work/ what is the difference between the two procedures? 
Why couldn't the instructions read, that all recombinant 
DNA research, regardless of its funding source but 
carried out in an institution receiving NIH funds, must 
be treated as if the research is NIH-funded? In that way 
[A-212] 
