FRIENDS OF THE EARTH 
620 C Street, S.E., Washington, D. C. 20003 
(202) 543-4313 
David Brower, President 
October 23, 1978 
Mr. F. Peter Libassi, 
General Counsel 
Department of Health, Education, and Welfare 
200 Independence Ave. SW Rm. 722 A 
Washington, D.C. 20201 
Dear Peter, 
To begin, I would like to thank you again for the opportunity 
to present our views on the procedural aspects of the proposed 
revised guidelines for recombinant DNA research. The overwhelming 
opinion of all those who have been involved since the public 
hearing on September 15th, is that our concerns are finally be- 
ing "heard." Some of us are even optimistic enough to believe 
that our suggestions may even be implemented. This is a very 
different climate than that to which we have become accustomed, 
and I wish to thank you and Secretary Califano for your concern 
and commendable involvement. We sincerely hope that HEW's over- 
sight will not end with these deliberations; we have found it a 
considerable improvement over the NIH. 
I would like to briefly outline our position on the institu- 
tional biosafety committees as it was discussed in our meeting 
on October 18th, taking into account your comments. 
We are also painfully aware of the unsatisfactory nature of 
present federal regulatory mechanisms, and do view the IBC as a 
worthwhile experiment to be supported. On the other hand, it 
will never work unless the membership is carefully balanced to 
avoid the "fox guarding the chicken coop" problem. I think you 
understand our concerns, -and I will not further elaborate other 
than to refer you to my testimony for one possible model, and to 
reiterate that no matter what the specified make-up, if the. in- 
stitution chooses all the members, the best laid plans can and 
will be circumvented. 
Assuming the make-up of the biosafety committees is more to 
our liking, we still have problems with the particular authority 
that has been delegated to the IBC's. We could support increased 
inspection authority at the local level as a much more effective 
alternative to a federal inspection team. Members of the IBCs 
or its agent, the biological safety officer (BSO) should be re- 
quired to inspect the labs on a regular basis. 
While that particular job is not given to them in the guide- 
lines, the type of authority (assessment of risk) that is being 
delegated is inappropriate at the local level for the following 
reasons : 
[A-432] 
Committed to the presentation, restoration, and rational use of the ecosphere 
