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NATIONAL JEWISH HOSPITAL 
AND RESEARCH CENTER 
NATIONAL ASTHMA CENTER 
3800 EAST COLFAX AVENUE 
DENVER, COLORADO 80206 
DoDcLOCS) 
303/388-4461 
AN INSTITUTE FOR RESPIRATORY AND IMMUNE DISEASES 
November 10, 1982 
Dr. William J. Gartland 
Director, Office of Recombinant DNA Activities 
Rm 4A52, Bldg 31 
National Institutes of Health 
Bethesda, Maryland 20205 
Re: Comments on Revised Guidelines 
Dear Dr. Gartland, 
More and more scientists are using recombinant DNA techniques, but 
many new users are unfamiliar with the new Guidelines and are confused by 
outdated information. Present documentation, particularly the Federal Register 
editions, are extremely tiresome to read and interpret. Consequently, our 
committee spends a lot of time trying to explain the guidelines to new 
investigators, before we get down to applying the guideline to an experimenter's 
particular project. I assume more readable editions of the Guidelines are 
forthcoming. In addition, I suggest a one-page, condensed "Guide to the 
Guidelines" that would be understandable by the uninitiated, and that would 
sort out the great majority of cases that are exempt. Such a "Guide" might 
be included in NIH grant application materials. Scientists would then not 
start out in relative ignorance when contemplating recombinant DNA experiments 
or dealing with IBC's. 
Our Committee meets, as needed, usually several times a year. As chairman, 
I answer questions about recombinant DNA (e.g.. Are these experiments exempt?) 
about once a week. I maintain a file of memoranda cataloging recombinant DNA 
work at our hospital (both exempt and non-exempt), so that I can keep track 
of all recombinant DNA activity, and answer questions from persons inside 
and outside the hospital. 
We have been fortunate in not encountering serious problems with the 
Guidelines; perhaps because we have not received requests to perform experiments 
that could be thought to have high potential risk. 
Our Biosafety Committee, in conjunction with our full-time Biosafety 
Office, oversees radiation, pathogenic microorganisms, and recombinant DNA 
activities. It would be nice if the Guidelines were complementary to the 
Center for Disease Control recommendations for pathogenic microorganisms. 
For example, perhaps the description of PI, P2, P3, P4 could be generalized 
to apply to both pathogen and recombinant DNA containment. 
bp 
[ 542 ] 
Michael J. Pa 
Associate Pro 
Chairman, Bio 
Sincerely 
