Document 21 
Boylor College of Meolicine 
DEPARTMENT OF VIROLOGY AND EPIDEMIOLOGY • 713 790-4443 
October 21 , 1976 
Dr. Donald S. Frederickson 
Di rector 
National Institutes of Health 
Bethesda, Maryland 20014 
Dear Don: 
Thank you for sending the copy of the Draft Environmental Impact 
Statement. The Statement is couched in terms which should allay the 
concerns of a wide variety of individuals who may be opposed to this 
type of research. 
However, I am personally concerned with the policies of the NIH 
vis a vis those of Great Britain's Genetic Manipulation Advisory 
Group (GMAG). According to the guidelines released last month by the 
GMAG, it will be possible, for example, to perform "shotgun" cloning 
experiments with DNAs of animal viruses non-pathogenic to man using 
the equivalent of a P2 EK2 containment system. The GMAG has also 
deliberately avoided the precise assignment of experiments with named 
organisms to particular categories and has recommended that experiments 
which they consider do not present a serious hazard, i.e., viruses 
non-pathogenic to man, should go ahead without delay. 
In view of Great Britain's stance, and the probability that the 
international scientific community will follow suit, I feel that the 
NIH should address itself immediately to these relaxed guidelines. 
This can be done in the Environmental Impact Statement, which will 
provide the first public forum on the regulation of recombinant DNA 
experiments and their possible environmental implications. In so 
doing, the NIH can still justify the stringency with which it formu- 
lated the guidelines. On the other hand, we now have the decisions 
reached by the GMAG which can serve as an independent yardstick for 
gauging our courses of action with the further possibility of amending 
them. Finally, the scientific and lay public alike will be made aware 
of the fact that unless the NIH adopts a reasonable posture, recom- 
binant DNA technology in the United States and the benefits which 
shall accrue may lag behind those of other countries. 
Sincerely yours. 
Joseph L. Melnick 
JLM/jg 
Appendix K — 111 
TEXAS MEDICAL CENTER • HOUSTON TEXAS 77030 
