NATIONAL SCIENCE FOUNDATION 
WASHINGTON. D C. 20550 
OFFICE OF THE 
DIRECTOR 
September 28, 1978 
Dr. Donald S. Fredrickson 
Director, National Institutes of Health 
Bethesda, Maryland 20014 
Dear Don: 
We support and concur in the substance of the proposed revised guidelines insofar 
as they relate to the conduct of experiments involving recombinant DNA. The 
proposed revised guidelines are clearly stated and make prudent use of available 
facts. They set standards that protect our health and environment from 
conjectural risks, while permitting research to proceed with adequate but 
unemcumbering caution. 
We believe that proper separation has not been made between the National 
Institutes of Health's (NIH) responsibility for the development of the guidelines and 
the designation of certain aspects of their implementation and interpretation. This 
new tool of biological research will be used to enhance the mission of Federal 
agencies other than NIH, principally the Department of Agriculture (DOA), the 
Department of Energy (DOE), and the National Science Foundation (NSF). As long 
as safety is not compromised, and uniform standards are used each should pursue its 
goals expediently. By removing the flexibility in the current guidelines that allows 
other agencies to use discretionary powers, the proposed revised guidelines in 
effect subject the research of other agencies to the additional requirement for NIH 
approval procedures. This approaches establishing a regulatory role for NIH. Just 
as the proposed revised guidelines recognize that the responsibilities of the 
Institution Biosafety Committees (IBC) must be enhanced to make them partners in 
implementing the guidelines, so too, should the discretionary powers of other 
research agencies be recognized. 
We believe each agency can exercise its independent responsibility without 
diminishing the central role of NIH in coordinating and communicating all 
decisions. Specifically, the Recombinant DNA Advisory Committee (RAC) should 
be recognized as a de facto national advisory body for all agencies. Accordingly, 
RAC recommendations could be considered directly by each agency. You pointed 
out in your Decision Document that, in addition to recommendations from RAC, 
you may seek additional advice for NIH purposes. In the same vein, we believe that 
other agencies should have this option. No agency should unilaterally act on a RAC 
recommendation; but within 30 days after each RAC meeting, representatives from 
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