DeWitt Stetten, Jr. 
Page 2 
March 26, 1976 
Dr. Frederickson for consideration at the 
April 1-2 meeting focus attention on the problem. 
My own vote, if I were present, would be in favor 
of raising the requirement to P3, or the higher 
level of EK2 in biological containment, in each 
of the instances where the issue is posed. 
b. The meeting brought attention again to insects, 
embryonic DNA, SV40 DNA, certain hazards with 
prokaryotes, and whole plants. The suggestions 
in the issues posed by Dr. Frederickson for streng- 
thening the guidelines on these matters appear to 
this lay observer to be desirable, reasonable, and 
adequate . 
2. Implementation by NIH 
Preparation of guidelines is only a first step; 
the big problem for the future is adherence to the 
guidelines. It would be very unfortunate if the 
committee's labors were unrewarding because of non- 
adherence, and also if such nonadherence led to im- 
position of controls that would frustrate scientific 
research. Adherence_ will Jbe ( a major problem for a 
variety of reasons ; '^'soiSe ' wi il w'amt to do ^rerbombinant re- 
search even when the conditions set by the guidelines 
cannot be met; and academicians are reluctant to 
"supervise" their colleagues. To make the guide- 
lines effective on grantees these things appear to be 
necessary : 
1) * Broaden the local committee to include some 
one responsible for occupational safety, a student, a 
representative of the University administration, per- 
haps an informed person from outside the University. 
2) Require certification on grant applications 
that conditions in the guidelines have been or will be 
met, such certification to be made by the investigator, 
the committee, and the University. The last of these 
is important because the University's reputation and 
its liability to suit will make its administrators 
careful . 
3) Require recertification of compliance with 
guidelines at periodical intervals. 
[ 503 ] 
