Medical Repair Laboratories Inc. 
CERTIFICATION AND REPAIR SERVICE 
357 Glen Cove Road 
Greenvale, N. y. 11548 
( 516 ) 759-1510 
September 21, 1978 
Director 
National Institutes of Health 
Bethesda, Maryland 20014 
Subject: Proposed Revised Guidelines, Recombinant DNA Reasearch 
Ref erence : Federal Register 43, 146 (July 28) 1978 
Dear Dr. Fredrickson: 
We have reviewed the proposed revised guidelines for Re- 
combinant DNA Research as published in the Federal Register. 
While the document is generally very excellent, we believe 
there are some points which require amplification. They are 
as follows: 
A. Add to paragraph II-B-2-b , II-B-4-b-(l) and II-B-4 -b- ( 2 ) 
the following statement: “Biological Safety Cabinets shall be 
certified in situ upon installation, if moved or relocated, and 
at least annually". Add to paragraph II-B-3-b and II-B-4-b-(3) 
the following statement: "Biological Safety Cabinets shall be 
certified in situ upon installation, if moved or relocated, 
and at least annually and preferably semi-annually". 
Many users are unaware of the need for certification of 
new units in situ , and believe that the manufacturer's factory 
certification is adequate. While section IIIB of the Labor- 
atory Safety Monograph (P130, second paragraph) states that 
cabinets should be certified under the conditions noted above, 
the statement is not a requirement, and the Monograph is con- 
sidered a "supplement to" rather than a part of the guidelines 
and has no regulatory impact. We have had the experience that 
investigators working with recombinant DNA have refused to have 
their cabinets recertified annually because the guidelines did 
not require it (reference our letter to Dr. Gartland of July 6, 1978) 
[A— 218] 
