THE UPJOHN COMPANY 
KALAMAZOO. MICHIGAN 49001. USA 
TELEPHONE (616) 323-4000 
January 20, 1983 
W. J. Gartland, Jr., Ph.D., Director 
Office of Recombinant DNA Activities 
National Institutes of Health 
Bethesda, Maryland 20205 
Dear Dr. Gartland: 
The Upjohn Biosafety Review Committee (UBRC), functioning as an Institutional 
Biosafety Committee (IBC), is pleased to respond to the questions set forth in 
your recent memorandum request for information. Our responses are presented 
in the same order as your questions, which I have restated for convenient 
reference . 
1 . What are the problems with the revised Guidelines? 
The Guidelines do not state that approval of an experiment for one 
laboratory constitutes approval of the same allowed experiment for 
other laboratories without additional approvals. This point should 
be set forth explicitly. 
The listing of newly approved experiments should be accompanied by 
a cumulative listing of all previously allowed experiments, to ob- 
viate the need to review all prior Recombinant DNA Advisory Committee 
minutes . 
2 . What things are taking large amounts of time? 
None. 
3 . What things are taking inappropriate amounts of time? 
None. 
4 . In what areas do you disagree with the RAC with regard to containment 
for a particular experiment? 
a. The continued listing of Actinomycetes as Fungal Agents in Appendix 
B-I-B-2 of the Classification of Microorganisms on the basis of 
Hazard is difficult to comprehend and should be corrected. The 
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