IBA 
Director! 
Officer* 
President 
Ronald E. Cape 
Cetus Corporation 
Vice President 
Gabriel Schmergel 
Genetics Institute 
Secretery 
Hollis G. Schoepke 
G. D. Searle S Company 
Treasurer 
John E. Donalds 
The Dow Chemical Company 
Hugh A. D'Andrade 
Schering-Plough Corporation 
Richard L. Easterday 
Pharmacia, Inc. 
J. Leslie Glick 
Genex Corporation 
John R. Norell 
Phillips Petroleum Company 
David J. Padwa 
Agrigenetics Corporation 
George B. Rathmann 
Amgen 
Industrial Biotechnology Association 
21 1 5 East Jefferson Street 
Rockville, Maryland 20852 
Telephone: (301 ) 984-9598 
Harvay S. Price 
Executive Director 
February 1 , 1984 
Dr. William J. Gartland, Jr. 
Director, Office of Recombinant 
DNA Activities 
Building 31 , 3B10 
National Institutes of Health 
Bethesda, Maryland 20205 
Re: Federal Register notice for February 6 RAC meeting, 
49 F.R. 696 (January 5, 1984) 
Dear Dr. Gartland: 
The comments below are submitted on behalf of the Industrial 
Biotechnology Association, a trade association representing many of the 
leading companies engaged in commercial biotechnology activities. A cur- 
rent membership list is attached. 
In NIH's consideration of its oversight boundaries, we would like to 
encourage the Recombinant DNA Advisory Committee (RAC) to continue scien- 
tific review of experiments concerned with the environmental release of 
organisms modified using recombinant DNA techniques, and to work closely 
with other Federal agencies in exercising this responsibility. As Dr. Ber- 
nard Talbot, Deputy Director of the National Institute for Allergy and 
Infectious Disease, points out, the NIH Guidelines were originally formu- 
lated to address laboratory research issues. The RAC, however, has firmly 
established a valuable tradition of going beyond this original intent. It 
has, for example, successfully assisted in the development of procedures 
for review and containment of large-scale processes involving recombinant 
organisms; processes that are becoming important for the pharmaceutical 
industry . 
[641] 
