GENEiViOOR 
Genencor. Inc. 
1 80 Kimcail Wa\ 
South San F r arc:sco. CA 94080 
41 s 742-7500 
Telex 67^ ■'263 GENEN US 
May 23, 1988 
Dr. William J. Gartland, Jr. 
Executive Secretary 
Recombinant DNA Advisory Committee 
National Institutes of Health 
12441 Parklawn Drive 
Suite 58 
Rockville, MD 20852 
Dear Dr. Gartland: 
Genencor, an enzyme manufacturing company, is writing in support of the 
proposed amendment to appendix C-IV of the NIH Guidelines for Research 
Involving Recombinant DNA Molecules proposed by Dr. Joseph R. Fordham 
of Novo Laboratories, Inc. 
As stated by Novo, Bacillus licheniformis should be added to Appendix 
C-IV. There is no scientific reason why B. licheniformis should not be 
treated identically to B. subtilis as a host for the rDNA experiments 
described in Appendix C-IV. It is a nonpathogenic organism with a long 
history of safe industrial use and is closely related taxonomically to 
B. subtilis . all of which is adequately supported in the Novo proposal. 
By incorporating Bacillus licheniformis into Appendix C-IV, NIH will be 
giving clearer guidance to IBC's on the appropriate containment for 
rDNA organisms with B. licheniformis as the host. This guidance should 
benefit both the IBC's and NIH-RAC as there will be no opportunity for 
IBC's to be confused as to the appropriate containment for such 
cultures and, therefore, they will not have to petition NIH-RAC for 
guidance, as is currently being done. 
Genencor thanks the NIH for the opportunity to comment on this issue. 
We hope that these comments are useful to NIH-RAC as they deliberate 
this issue. 
Sincerely, 
Alice J. Caddow 
Director of Regulatory 
and Environmental Affairs 
[372] 
Recombinant DNA Research, Volume 13 
