IV-A-l-C Registration of research - Requiring institutions to register with NIH 
all projects approved by the IBC should be limited to NIH supported research and 
recombinant DNA research supported by non-federal sources. For Federally 
supported research other than NIH, each agency should maintain its own registry, 
which can be routinely added to the NIH registry. This will more effectively 
capture information about intramural research at national laboratories and 
experiment stations and will more accurately track proposed extramural research. 
IBC's approve MUA's when proposals are submitted to funding agencies. Final 
action on those proposals may not take place until 6-9 or more months later. At 
that time a project can be funded or disapproved. If funded, it is possible the 
recombinant DNA experiments may be specifically excluded from support. 
Reporting of these details by the cognizant agency is a more effective mechanism. 
With respect to registration it would be helpful if the term research "project" were 
defined. Can a single grant or MUA involve more than one project? If so, must 
each be registered separately? 
I hope that the next version of the guidelines will accommodate NSF concerns 
expressed in this letter. Interagency cooperation and coordination and drawing 
proper boundaries between jurisdictional authority has been effective in the past. 
This should continue in order to avoid confusion within the scientific community 
and to accomplish our common goal of enhanced research, minimum delay and 
appropriate precautions for safety. In closing, you and your staff should receive 
strong praise for the responsible and effective development of national standards 
for the conduct of research using recombinant DNA techniques. 
Sincerely yours, 
Richard C. Atkinson 
Director 
[A-396] 
