STANFORD UNIVERSITY MEDICAL CENTER 
STANFORD, CALIFORNIA 94305-5307 
DEPARTMENT OF BIOCHEMISTRY 
Stanford University School of Medicine 
September 3, 1987 
Area Code 41 5 
723-6161 
Director 
Office of Recombinant DNA Activities 
12441 Parklawn Drive 
Suite 58, 
Rockville, MD 20852 
Dear Director: 
I have strong objections to the recommended changes in the NIH guidelines 
proposed in the Federal Registry, vol. 52, number 154, Tuesday, August 11, 
1987. On page 29800, under roman numeral I, proposed ammendments to Section 
1C, the proposed change recommended by Edward Lee Rogers, of Washington D.C., 
is to substitute language in the guidelines that is clearly written by a 
lawyer. I find the whole paragraph incomprehensible. As Chairman of the 
Stanford Biosafety Committee I would be totally unable to interpret this 
paragraph to fellow scientists. I think it is essential that the guidelines 
not be filled with legal language that is not understandable by the scientist 
conducting these experiments. One of the strength of the guidelines is they 
are written in simple, clear english, that most people without legal training 
can understand. Since I don't understand the paragraph I cannot decide if I 
object to what it supposedly means. 
On page 29801, it states that Biosafety level 1 for plants (BL 1-P) is 
recommended for experiments for which there is no recognizable or projectable 
risk to the environment in the event of accidental release or for which there 
is convincing biological evidence that precludes the possibity of survival, 
transfer or dissemination of the recombinant DNA molecules into the 
environment. However, on page 29804 number 9 1C, states a sign incorporating 
the universal biohazard symbol is posted on the greenhouse access doors, it 
seems unwise to use the biohazard symbol when the organisms that are being 
used are believed to be totally non-hazardous . Since this will be the most 
common type of experiment, investigators will not take the biohazard symbol to 
indicate anything significant. I believe the biohazard symbol should only be 
used on real biohazards. If it is desired to use the biohazard symbol for 
hypothetical hazards then it should be limited to BL3 or higher. I believe 
this action is essential so that the universal biohazard symbol will retain 
it's meaning. 
Sincerely 
Ronald W. Davis, Ph.D. 
Professor of Biochemistry 
Chair, Administrative Panel on Biosafety 
[ 350 ] 
Recombinant DNA Research, Volume 13 
