AR EA CODE 6 
PHONE 262-21 
MEDICAL CENTER 
UNIVERSITY OF WISCONSIN • MADISON, WISCONSIN 53706 
McARDLE LABORATORY 
FOR CANCER RESEARCH 
Hay 7, 1979 
Dr. W. Gartland 
Office of Recombinant DNA Activities (ORDA) 
NIH 
Building 31 , Room 4A52 
Bethesda, MD 20014 
Dear Bill: 
I read the RAC Meeting Announcement (Part III) in the Federal Register 
of April 13, 1979 (Vol. 44, No. 73, pp. 22304-6) and I would like to 
support strongly the proposals which relax the regulations for the use 
of the recombinant DNA technique. In particular I shall discuss proposals 
3,5,6,11a and 12. 
Proposal 3 ‘ The new version of III-C-6 which permits transfer of EK2- 
cloned eukaryotic DNA into heterologous eukaryotic cells is much more 
logical than the old version which has been restricting the transfer to 
the homologous organismsonly . Many experiments on the heterologous 
transfer were done in the 1960s and 1970s without any specified 
containment and with no adverse effects. Since we have developed the 
first selective system (HAT medium) for HGPRT + mammalian cells [Enclosure 
W. Szybalski , E. H. Szybalska and G. Ragni : Genetic studies with 
human cell lines. National Cancer Institute Monograph No. 7: pp. 75* 
89 (1962)] and performed the first successful DNA-mediated transformation 
of mammalian (human) cells using this system based on our HAT medium 
[Enclosure Jl: Szybalska, E. H. and Szybalski, W.: Genetics of human 
cell lines. IV. DNA-mediated heritable transformation of a biochemical 
trait. Proc. Natl. Acad. Sci . USA 4jB: 2026-2034 (1962)], I have 
personally done many experiments at that time testing DNA from various 
organisms for Its capacity to transform our HGPRT human cells. Although 
I encountered at that time some unpleasentness and scare-scenario 
publicity, no trace of any dangers or untoward effects were encountered 
in my two-year studies. Since these experiments were then and now 
permitted and are unregulated, it would be totally illogical to restrict 
or regulate analogous experiments when purified specific fragments 
of DNA are used and they are just attached to the pieces of innocuous 
phage X DNA. 
Since our selective HAT technique is now widely and successfully 
used in other countries both for homologous and heterologous transformation 
using recombinant DNA, any further restricting of these experiments In the 
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