Dr. Donald S. Fredrickson 
Page 2 
September 22, 1978 
that will foster the dissemination of new knowledge, yet 
protect the company's proprietary interests. We would 
consider these concepts equally important for academic 
laboratories . 
(2) IV. -C. -2. Voluntary Registration and Certifi - 
cation . 
The proposed guidelines provide that institutions not 
required to comply with the guidelines may nevertheless 
register recombinant DNA research projects with NIH by 
submitting the appropriate information to ORDA. Further, 
the proposals provide that NIH will accept requests for 
certification of host vector systems by the institution 
and that the submitter must agree to abide by the physical 
and biological containment standards of the NIH guidelines. 
It is our understanding that a number of research 
institutions not subject to the guidelines (including 
ours) support them in principle and abide by the physical 
and biological containment standards delineated therein. 
We recommend that the voluntary registration and certi- 
fication procedures be extended to provide for sufficient 
latitude to encourage the voluntary identification of 
facilities engaged in recombinant DNA research and to pro- 
vide NIH with information on private research laboratory 
and industrial research recombinant DNA efforts. This 
should be accomplished without subjecting the participants 
to a possible loss of confidential information and conse- 
quent competitive disadvantages through Freedom of Infor- 
mation requests. It would appear desirable for NIH to 
encourage the voluntary identification of facilities 
engaged in recombinant DNA research, the identification of 
senior scientists responsible for such activities within 
private academic and industrial research laboratories and 
the acquisition of information by NIH on the type of 
physical containment at these facilities. 
The revised guidelines should expressly provide the 
opportunity for identification to NIH of facilities and 
projects at the discretion of the private industrial con- 
cern and for the ensuing dialogue which can occur regarding 
the scientific characteristics of such work, under these 
procedures, we would not contemplate that NIH's role would 
require approval of projects or facilities in a regulatory 
sense. We perceive, however, that public interest can be 
[A-273] 
