Stauffer Chemical Company 
1200 S. 47th St. / Richmond, CA 94804 / Tel. (415) 231-1000 / TWX (910) 382-8174 
December 27, 1982 
Di rector 
Office of Recombinant DNA Activities 
Building 31, Room 4A52 
Bethesda, MD 20014 
Attn: William J. Gartland, Jr., Ph.D. 
Dear Dr. Gartland: 
Your request to answer the following questions concerning the functioning 
of the IBC's under the NIH Guidelines and some of the problems associated 
therewith, will be answered according to the manner in which the questions 
were presented. 
1. What are the problems with the revised Guidelines? 
The Guidelines, as last presented on August 27, 1982, seem to be in 
relatively good shape. The one exception that is bothersome to us 
is the fact that all organisms not so listed in the Guidelines are 
considered to be prohibitive to work with until permission has 
been obtained or a petition has been sent to the RAC Committee. 
2. What things are taking large amounts of time? 
At this point in our particular research program we are working with 
systems which can be cleared by the local IBC, so very little time 
is being spent on gaining clearance. 
3. What things are taking inappropriate amounts of time? 
Again, the answer is that all of the things with which we are 
working are well within the scope of PI or HV1 systems and require 
very little time. 
4. In what areas do you disagree with the RAC with regard to contain- 
ment for a particular experiment? 
None. They appear to be well worked out and I think containment is 
appropriate for the types of experiments and organisms that have been 
shown. 
5. In what ways are the Guidelines too restricted or too stringent, or 
too relaxed? 
The Guidelines could be relaxed more with respect to the types of 
microorgani sms which are acceptable for working without petitioning 
to the RAC for permission to do so. 
Ut UUIbNt 
TECHNICAL CENTER 
WESTERN RESEARCH 
Stauffer 
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