Lilly Research Laboratories 
A Division of Eli Lilly and Company 
307 East McCarty Street 
Indianapolis. Indiana 46285 
Irving S Johnson, Ph D 
Vice President 
February 1 , 1983 
Dr. William J. Gartland, Jr., Director 
Office of Recombinant DNA Activities 
Department of Health and Human Services 
National Institutes of Health 
Beth es da, MD 20205 
Dear Dr. Gartland: 
We wish to comment on the proposed process of annual updates for 
the program to assess the risks of recombinant DNA research ( Fed. 
Reg. 47 , No. 235, p. 55104, December 7, 1982): 
Since no added risks have been identified under several 
"worse case" experimental protocols, any need for emphasis in 
the form of annual updates has disappeared. Normal channels 
of scientific communication can deal appropriately with the 
results of those studies that are worthy of publication. We 
recommend that the risk-assessment program be treated in the 
same manner as any other NIH-funded endeavor, both in terms 
of peer review of proposals and announcement of results. 
Sincerely yours, 
Ir , i 
Lilly Institutional Biosafety Committee 
rl 
[ 604 ] 
