The Ohio Stste University 
Department of Genetics 
1735 Neil Avenue 
Columbus, Ohio 43210 
Phone 614 422-8084 
November 1, 1982 
Dr. William J. Gartland, Jr. 
Office of Recombinant DNA Activites 
National Institutes of Health 
Building 31, Room 4A52 
Bethesda, Maryland 20205 
Dear Dr. Gartland: 
This is in response to your memorandum requesting comments on the 
NIH Guidelines for Research Involving Recombinant DNA Molecules as re- 
vised during 1982. 
The Ohio State University IBC has not specifically discussed details 
of the new Guidelines, and the following comments are my own interpret- 
ations of the feelings of the IBC at this time. 
The IBC originally was strongly in favor of the original proposal 
to greatly relax the Guidelines. However, we agree with the RAC that 
an extreme relaxation of the Guidelines might invite public criticism 
and interference by local governments and citizen groups in the conduct 
of recombinant DNA research. Consequently, although we would have pre- 
ferred more relaxed Guidelines, and feel that these would probably have 
been acceptable at our institution and in our community, we cannot quarrel 
with the RAC's decision. 
Our institution has a separate committee for general biosafety. 
Most of the experiments conducted at this university are exempt or re- 
quire only minimal containment (PI or P2). Consequently, our workload 
is small. Most of the work of reviewing projects, interviewing person- 
nel, and inspecting laboratories for approval is carried out by sub- 
committees. The IBC meets as a whole only three to four times each year; 
most of our meetings in the past lk years have been concerned with estab- 
lishing formal procedures for our work, and then revising these when the 
Guidelines were revised. 
Incidentally, for exempt experiments we require that the investigator 
file with the IBC a letter briefly stating the source of DNA being cloned, 
the vector, the host, the containment levels, and the rooms where the 
work is done. This gives us an opportunity to assure ourselves that the 
proposed experiments are indeed exempt and helps us keep track of the 
overall level of recombinant DNA research being done at The Ohio State 
Uni versity. 
Sincerely 
CWB: jks 
C. William Birky, Jr. 
Professor of Genetics 
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