Document 7 
6724 Towne Lane Court 
McLean, Virginia 22101 
29 September 1976 
Dr. Donald S. Fredrickson 
Director 
National Institutes of Health 
Bethesda, Maryland 20014 
Dear Dr. Fredrickson: 
The draft Environmental Impact Statement on Guidelines for Research 
Involving Recombinant DNA Molecules is a very lucid, complete, and 
useful document. The description of potential risks and benefits of 
such research is clear and impartial. 
It might be useful to have a very brief discussion on modes of 
spread of enteric organisms such as coli , and mention of epidemiology 
of diseases caused by enteric organisms in the section on p. 52, part b 
(Sanction of the iise of the bacterium Escherichia coll as a recipient 
for recombinant IWIA molecules). While it is true that coli strains 
are Intimately associated with humans and other animals, this association 
is potentially harmful. It might be helpful to state clearly that E. coli 
K-12 is very attenuated in this regard. It is also a bit disappointing 
(but not unexpected) that EK-2 organisms have not been developed rapidly. 
Some of the same arguments used in the discussion on pages 18-19 (The 
effect of foreign DNA on the survival of recipient species (host cells or 
viruses)) that foreign MJA is likely to reduce survival and multiplication 
of recipient organisms, apply to organisms containing many mutations such 
as "disarmed" K-12. Thus the EK-2 candidates are likely to have much 
longer generation times and stringent growth conditions than the parent 
strains. These features, required for reducing risk, may also ultimately 
reduce the usefulness of EK-2 and EK-3 strains. 
On the whole the Impact statement is a fine document. I appreciate 
your sending it to me for comment. 
Sincerely, 
Elena 0. Nightingale, M.D. , Ph.D. 
EON :1m 
Appendix K — 24 
