Department of Biological Sciences 
State University of New York at Albany 
January 25, 1983 
Dr. William J. Gartland, Jr. 
National Institutes of Health 
Office of Recombinant DNA Activities 
Building 31, Room 4A52 
Bethesda, MD 20205 
Re: Your memo soliciting comments on revised guidelines 
Dear Dr. Gartland: 
According to the guidelines, the IBC is responsible for the work 
done at the University and in insuring that the guidelines are followed. 
This is not simple to do because investigators make their own decisions 
on whether or not work that they are doing is exempt from the guidelines. 
Since they are not required to inform the IBC of the nature of the work 
being done, if in their opinion, it is exempt, it becomes difficult for the 
IBC to monitor compliance with the guidelines. 
The IBC at SUNY at Albany is reluctant to require that all investi- 
gators inform it of their activities even if exempt, since this is not 
specified by the guidelines. 
Hence it would be helpful, since the IBC is responsible for ensuring 
compliance, that the guidelines stipulate that the IBC should be informed 
of the nature of all major recombinant DNA experiments being done even if 
they are exempt. The IBC would then be cognizant of all work at the 
institution and could perform its functions in a more intelligent manner. 
If for other reasons this change is considered undesirable, then the 
guidelines should place the responsibility for compliance with the indi- 
vidual researcher and not with the IBC. 
Since all the work being done at SUNY is being interpreted by investi- 
gators as exempt, the IBC has not been required to meet regularly, the last 
meeting being held about a year ago. 
In general, our IBC approves of the trend to relax the guidelines and 
welcomes progress towards the ultimate phasing out of the guidelines. 
The IBC at Albany does not have any other responsibilities. 
Sincerely, 
Joseph P. Mascarenhas 
Chairperson, IBC 
JPM: rl 
1400 Washington Avenue, Albany, New York 12222, 518/457-3300 
[585] 
