Oklahoma State University 
OFFICE OF THE DEAN & DIRECTOR 
DIVISION OF AGRICULTURE 
College of Agriculture Agricultural Experiment Station 
Cooperative Extension Service 
STILLWATER. OKLAHOMA 74078-0500 
13 9 AGRICULTURAL HALL 
405-624-5398 
September 2, 1987 
Dr. William Gartland, Director 
Office of Recombinant DNA Activities 
12441 Parklawn Drive, Room 58 
Rockville, MD 20852 
Dear Dr. Gartland: 
In response to the Federal Register notice of August 11, 1987 (52 Fed. 
Reg. 29801-29814), "Proposal to Modify and Amend the 'Guidelines for Research 
Involving Recombinant DNA Molecules' to Refer Specifically to Research with 
Plants and Animals," the Committee on Biotechnology, Division of Agriculture, 
National Association of State Universities and Land-Grant Colleges offers the 
following comments: 
The Committee on Biotechnology was formed in 1982 to study and assess bio- 
technological research as it impacts the state university and land-grant 
college system. One of our major areas of concentration has been the regula- 
tion and oversight of research using recombinant DNA techniques. We have 
continuously advocated a system for oversight of all recombinant DNA research 
activities that emulates the system that has operated so successfully for more 
than a decade under the National Institutes of Health and the Recombinant DNA 
Advisory Committee. 
The proposed modifications and amendments to the NIH Guidelines in the 
August 11, 1987, Federal Register are prudent. We recommend their approval by 
the Recombinant DNA Advisory Committee and the Director of the National 
Institutes of Health. The modifications and amendments would set forth proper 
practices and conditions for plant and animal research with recombinant DNA 
techniques. More importantly, the changes would extend the step-wise review of 
recombinant DNA projects with detailed review at the local level and review at 
the national level for investigations with significant risk or unknowns. This 
system has operated safely for contained laboratory research since the 
inception of the Guidelines in 1976 and should be continued for application to 
plant and animal systems. 
Sincerely yours 
tr 
Recombinant DNA Research. Volume 13 
[341] 
