Dr. Donald S. Fredrickson 
Page 3 
September 22, 1978 
better served if private laboratories share with NIH infor- 
mation on their laboratory capabilities. Further, 
scientists within private research facilities, government, 
and industry should have enhanced opportunities for 
dialogue with the consequent assurance that recombinant 
DNA procedures are conducted in a safe and appropriate 
manner . 
(3) IV- A- 2 . Institutional Biosafety Committee . 
We believe that it is philosophically inconsistent to 
require that one or more members of the Institutional Bio- 
safety Committee (IBC) shall not be affiliated with the 
institution. Since there has been no demonstrated harmful 
product in the five years following the first questions 
raised about possible hazards (cf. Comments on the Proposed 
Guidelines, Federal Register, July 28, 1978, p. 33044), 
there is no need to imply the existence of a hazard not 
being dealt with by the committees on the basis of their 
present composition. Individual laboratories should have 
the option of securing one or more non-af filiated 
committee members, but the inclusion of such individuals 
should not be mandated, whenever members are appointed 
from outside the institution, their qualifications should 
be appropriate to enable them to examine, analyze, and 
interpret the problems associated with the experimental 
protocols and facilities being reviewed. 
(4) II-B-3-C- (7) . Exhaust Air Disposal . 
In earlier correspondence concerning the design and 
construction of one of our P3 laboratory facilities, we 
described an air disposal problem and our method of solving 
it (letter to Dr. W. Emmett Barkley, March 14, 1978, copy 
attached) . The Proposed Revised Guidelines do not address 
the possibility of recirculating treated exhaust air from 
a P3 laboratory to other parts of the building; we feel 
that this can be safely done and recommend including this 
alternative in the manner indicated in our letter. Dr. 
Barkley indicated his agreement with this extension of the 
guidelines in previous discussions. 
(5) III-A-a- (1) and III-A-2-a- (1) - (b) - (1) - (c) . 
Eukaryotic DNA Recombinants . 
The containment requirement of P2-EK2 for experiments 
with eukaryotic DNA of primates without the option of 
P3-EK1 seems inconsistent with the existence of that option 
[A-274] 
