UNIVERSITY OF CALIFORNIA 
BERKELEY • DAVIS • IRVINE • LOS ANGELES • RIVERSIDE • SAN DIEGO • SAN FRANCISCO 
SANTA BARBARA • SANTA CRUZ 
DAV ID PIERPONT GARDNER 
President 
OFFICE OF THE PRESIDENT 
BERKELEY. CALIFORNIA »1720 
WILLIAM R. FRAZER 
Senior Vice President — 
Academic Affairs 
September 4, 1987 
Dr. William Gartland 
Director, Office of Recombinant 
DNA Activities 
12441 Parklawn Drive, Suite 58 
Rockville, MD 20852 
Dear Dr. Gartland: 
I am responding on behalf of the University of California to the 
Notice of Proposed Actions Under Guidelines for Research 
published in the August 11, 1987, issue of the Federal Register 
(Vol. 52, No. 154). The recommended modifications, specifically 
those in section III, present guidelines for containment of 
genetically engineered animals, plants, and related 
microorganisms. The attachment includes comments on specific 
sections of the proposed guidelines. 
In spite of the limited time allowed for comment, we have 
discussed the suggested modifications with University scientists 
and administrators including Charles Hess, Dean of Agriculture 
and Environmental Sciences, at the Davis campus and Paul Boyer, 
Director of the University of California Biotechnology Research 
and Education Program. 
We recognize that the present public and legislative perceptions 
may require more specific regulations and guidelines than have 
existed up to now. On this basis the proposed changes and 
additions may serve a useful purpose. We feel it is important, 
however, to express our strong concern that creation of new rules 
may continue to promote the misconception that products and 
processes of genetic engineering are inherently dangerous and 
warrant special attention. 
That there is no scientific justification for such a perception 
was stressed in the position paper on release of genetically 
engineered organisms recently issued by a National Academy of 
Sciences committee. This report stresses the important 
conclusion that recombinant DNA techniques are powerful and safe 
processes. It reiterates the broadly-held scientific opinion 
that assessment of risks and determination of appropriate 
safeguards should be based solely on the nature of the organism 
and not on the process by which it was produced. Thus 
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