Chevron 
riDTUn Chevron Chemical Company 
940 Hensley Street, Richmond, CA 94804 
Research and Development January 23, 1984 
Agricultural Chemicals Division 
Director 
Office of Recombinant DNA Activities 
Building 31; Room 3B10 
National Institutes of Health 
Bethesda, Maryland 20205 
Dear Sir(s): 
In response to the FEDERAL REGISTER, Vol. 49, No. 3, notice, of January 5, 1984 
regarding guidelines proposed for recombinant DNA research the following comments are 
submitted for your consideration. 
I. PROPOSED AMENDMENTS OF THE NIH GUIDELINE 
1. The proposed amendment of Section III regarding the word "containment" 
serves to illustrate the very narrow thinking of certain critics of the proposal. 
Containment can mean "to retain within a given boundary"; it could be glove 
boxes, laboratories, greenhouses, small field plots or fields. We oppose the 
very narrow interpretation of "containment" which seems to refer only to 
laboratory or perhaps even sections of facilities within a laboratory. The word 
"containment" should remain in the guidelines, but be well defined as to its 
intended use. 
2. The proposed amendment of Section III- A. The reference to the need for 
environmental impact statements and/or environmental assessment and a 
requirement of such by NIH is entirely out of place in these guidelines and 
should be left entirely to those agencies legally endowed with authority to 
require them. There is no redeeming argument that can justify the duplication 
of environmental impact reports, and the excess amount of paper work and 
time that would be associated with it. We are opposed to the suggested 
change. 
II. QUESTIONS CONCERNING BOUNDARIES FOR NIH & RAC OVERSIGHT 
The following comments are submitted in response to the questions raised by the 
deputy director of the National Institute of Allergy and Infectious disease. 
1. We recommend the guidelines for NIH & RAC be expanded to include research 
that will be done outside a laboratory. These guidelines should include growth 
Chambers, Laboratories, greenhouses, small field plots and large field plots. 
Guidelines will be needed for this area of research as the technology expands 
in Agriculture. Knowledgeable and responsible people will be needed to 
address these issues and to develop reasonable guidelines to steer the research 
scientist toward the development of new products. 
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