UNIVERSITY OF WASHINGTON 
SEATTLE, WASHINGTON 9819S 
Program in Social Management of Technology 
September 21, 1978 
F. Peter Llbassi, Esquire 
General Counsel 
Department of HEW 
330 Independence Avenue S.W. 
Washington, D.C. 20201 
Dear Mr. Libassi: 
I greatly appreciate the opportunity afforded me to testify before you and 
other members of the Department's Task Force on the Proposed Revisions of 
the Guidelines Governing Recombinant DNA Research. Subsequently, I realized 
that there is a portion of my submitted written testimony which may be 
somewhat confusing, and I am taking the opportunity of this letter to submit 
a clarification. 
On page 19 of my written testimony I suggest language regarding the scope of 
concerns which ought to be within the purview of the IBCs. This should not 
be understood as conflicting with my earlier comments expressing reservation 
on the proposed scale of delegation of authority to the IBCs. I believe that 
federal approval (by an office such as ORNA) is necessary for all research 
proposals, experiments, changes in containment levels, and the like. The 
language I am suggesting on page 19 should be understood within the context 
of making it clear that the IBCs can supplement the NIH guidelines by local 
institutional policies. Thus the central phrase in the language I suggest 
is "compliance with NIH guidelines," and thus all the issues as to what the 
guidelines will contain, etc., are, in effect, incorporated by reference. 
If I can be of any further assistance to the Departmental review group and 
your staff, in working on these issues, please contact me. 
Philip L. Bereano 
Associate Professor 
PLBrrl 
[A-247] 
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