regulations based on whether or not genetic engineering 
techniques have been used are without a scientifically sound 
basis . 
We are concerned that the continued development of special 
regulations for genetic engineering research will discourage our 
faculty from entering into or expanding projects that fall under 
the guidelines. 
In summary, while we feel that the Guidelines may be useful under 
the present circumstances, there should be recognition that 
regulations based on whether genetic engineering has been used in 
obtaining a product are inherently unsound. We thus are 
recommending that a time limit be set for expiration of the 
Guidelines within several years unless experience in the interim 
proves that their continuation is necessary. In the attachment 
we propose specific language on such a time limit for 
consideration by the committee. This suggestion is given with 
the understanding that present or new regulations on biohazardous 
materials, regardless of their production by recombinant DNA 
production techniques, will suffice. 
Thank you for giving us the opportunity to comment. 
Sincerely 
William R. Frazer 
cc: Vice President Baker 
Vice President Farrell 
Recombinant DNA Research, Volume 13 
[337] 
