DNA/2 4 
EDF suggests that both NIH funded recombinant DNA activities and 
non-NIH funded recombinant DNA activities at institutions subject to 
the "Guidelines" be treated in a similar procedural fashion and that 
experiments not be initiated or altered until NIH approval is received. 
A recombinant DNA experiment poses the same threat to the health or 
environment no matter who pays for the experiment. EDF suggests that 
each person seeking to start or alter a recombinant DNA experiment at 
an institution subject to the "Guidelines" be required to file with 
the IBC a project registration statement, containing information 
identical to that contained in a MUA. The IBC should then conduct 
the review and certification described in Appendix C, sections II-A-d 
and II-A-e . The registrations should then be forwarded to NIH. Within 
5 days NIH should either approve the registration or specify the mod- 
ifications necessary to bring the project into compliance with the 
"Guidelines". Experiments may be begun or altered upon receipt by 
the IBC of NIH approval. In cases where modifications are required, 
the experiment should be allowed to proceed after the IBC certifies 
to NIH that the modifications have been completed. If adopted, this 
procedure would also apply to persons seeking to initiate a project 
contained in a competing grant application to NIH before NIH com- 
pletes its award procedure. 
Respectfully submitted, 
Leslie Dach 
Science Associate 
[A-359] 
