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January 21, 1987 
Dr. William Gartland, Jr. 
Executive Secretary 
Recombinant DNA Advisory Committee 
National Institutes of Allergy 
and Infectious Diseases 
Building 31 , Room 3B10 
National Institutes of Health 
Bethesda, Maryland 20892 
Re: Notice of Proposed Actions under NIH Guidelines 
for Research Involving Recombinant DNA Molecules 
Dear Dr. Gartland: 
Genentech, Inc. is involved in the research, development and 
manufacture of human pharmaceuticals produced via recombinant DNA 
technology. As such, we are interested in how commercial rDNA 
technology is affected by NIH policy and practices; and welcome this 
opportunity to comment on the proposed changes to the guidelines set 
forth in the Federal Register, 19 December 1986. 
We endorse the four proposed revisions contained in Sections I, II, III 
and IV. The refined definitions and clarifications will offer 
Institutional Biosafety Committees clearer guidance in determining 
appropriate complaince. They will also aid the commercial sector 
utilizing rDNA techniques in development and manufacture of new 
products, by establishing appropriate large-scale containment practices 
based on the knowledge gained through the use of industrial microbes. 
Comments on specific proposed actions follow. 
Recombinant DNA Research, Volume 1 1 
[275] 
