BioTechnica International, Inc. 
85 Bolton Street, Cambridge, Massachusetts 02140 (617) 864-0040 
Cable: BIOTECH 
Telex: 705219 
February 1, 1984 
Dr. William J. Gartland, Jr. 
Director, Office of Recombinant 
DNA Activities 
Building 31, Room 3B10 
National Institutes of Health 
Bethesda, MD 20205 
Dear Dr. Gartland: 
BioTechnica International, Inc. would like to comment on three 
items on the agenda of the February 6, 1984 meeting of the 
Recombinant DNA Advisory Committee (RAC) . 
BioTechnica ' s comments are as follows: 
1 . Ammendments to the NIH Guidelines Proposed by Messrs. 
Rifkin and Rogers . These should be rejected by the RAC for 
the reasons outlined by the Director, National Institute of 
Allergy and Infectious Diseases, on page 697 of the Federal 
Register of January 5, 1984. 
2. Questions concerning RAC and NIH Oversight Boundaries . We 
recommend a negative vote on all four questions. The RAC 
is currently the only repository of expertise on 
recombinant DNA in the Federal Government. Thus, limiting 
its involvement in issues relating to this area at this 
point in time is inappropriate. 
3. PI Growth Conditions for Plants . We recommend deletion of 
one proposed requirement for greenhouse operating 
conditions for the growth of plants containing recombinant 
DNA. This is the requirement that a PI greenhouse be 
equipped to provide either positive or negative air 
pressure, to be used in one mode or the other depending on 
the particular experiment. A requirement for positive air 
pressure for normal greenhouse operations will serve no 
useful purpose that we can envision. Furthermore, we 
believe that negative pressure to contain airborne 
propagules is not necessary because, by the very nature of 
the PI classification, the potential risks associated with 
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