Donald S. Fredrickson, Director 
21 September 1978 
Page 2 
One other provision of Section IV requires clarification. Paragraph 
IV-A-4-g, as written, permits the investigator to petition NIH, after notify- 
ing the IBC, for exceptions or exemptions to the proposed guidelines. While 
paragraph IV-A-4 implies that such petitioning would be done on behalf of the 
institution, it is possible that an investigator might seek exception or 
exemption against the wishes of the IBC, simply notifying the committee that 
he will take such action. Potential differences in interpretation of paragraph 
IV-A-4-g could be avoided by revising the paragraph to read "Petitioning NIH, 
after receiving the approval of the IBC, for exceptions or exemptions to these 
guidelines. " 
We appreciate the opportunity to respond to the proposed revisions of 
guidelines governing research with recombinant DNA and hope our comments will 
be given consideration. 
JBLilfr 
cc: Donald T. Witiak, Chairman 
Institutional Biohazards Committee 
[A-225] 
