University of Wisconsin-Madison 
LABORATORY OF GENETICS 
406 Genetics Building 
Madison, Wisconsin 53706 
0. Smithies 
Office: (608) 262-2976 
Laboratory: (608) 262-1047 
April 30, 1979 
Dr. Donald S. Fredrickson, Director 
National Institute of Health 
Dept, of Health, Education and Welfare 
9000 Rockville Pike 
Bethesda, Md . 20014 
Re: Recombinant Advisory Committee Meeting 
scheduled for May, 1979 
Dear Dr. Fredrickson: 
I write with regard to two modifications to the NIH Guidelines which are 
to be proposed at the May, 1979 meeting (see Federal Register, April 13, 1979). 
My comments relates to:- 
(i) The proposal by RAC to replace the previously recommended section III-C-6 
with a more specific statement :- 
"III-C-6. Transfer of cloned DNA segments to eukaryotic organisms. 
DNA from any nonprohibited source [Section I-D] which has been cloned 
and propagated in E. coli under appropriate physical containment 
conditions, may be transferred with the E. coli vector used for 
cloning to a eukaryotic organism or cells in culture and propagated 
under conditions of physical containment comparable to PI and 
appropriate to the organism under study. [2A] 
and (ii) to the proposal by Dr. Wallace Rowe, a member of RAC, on Exemptions 
under I-E-5:- 
"Those recombinant DNA molecules that are propagated in cells in 
tissue culture and that are derived entirely from non-viral components 
(that is, no component is derived from a eukaryotic virus) or that 
contain no more than one-fourth of the genome of a eukaryotic virus 
are exempt from the Guidelines." 
