AREA CODE 6 OB 
PHONE 262-2177 
McARDLE LABORATORY 
FOR CANCER RESEARCH 
MEDICAL CENTER UNIVERSITY OF WISCONSIN • MADISON, WISCONSIN 53706 
August 16, 1979 
Dr. William J. Gartland 
Office of the Recombinant DNA Activities 
N.I.H. (Bldg. 31 “ room 4A52) 
Bethesda , MD 2001 k 
Dear Bill: 
In response to the July 31,1979 announcement in Federal Register, 
Vol . bb (1979) PP- ^5o 88-9, I am submitting the following comments 
and proposals: 
1 . Proposed Exemption for E . col i K-12 Host-Vector Systems . 
I am supporting this proposal in principle, but I consider the 
original simpler version by Rowe and Campbell as preferable, since the 
latter is free of unnecessary bureaucratic requirements and paper work. 
This is a scientifically justified and long-overdue change, and does 
not require any political compromises, just to appease the handful 
of perennial critics of the recombinant DNA technique. 
2. Proposals 2~5 should be approved. 
3. Since the inadvertent formation of very weak pathogens is millions 
of times more probable than formation of more serious pathogens (if 
one assumes that this highly hypothetical event could ever happen), 
such weak pathogens would constitute an ample warning before any 
serious risks could be realized [see my letter published in the 
enclosed reprint from TIBS b (1979) p. N 1 90 ] . I proposejtherefore, 
that the NIH Guidelines be suspended until there are confirmed cases 
of any mild afflictions due to weak pathogens or environmental pests 
caused by the recombinant DNA technique. Please include this 
proposal for consideration during the future meeting of the RAC. 
b. In this vein, I believe that the proposed supplement to the NIH 
Guidelines [Feder. Reg., bb (1979) 45868-9 ] is premature, unnecessary 
and coercive. 
Please let me know whether I should supply any additional materials 
as to secure the inclusion of my No. 3 proposal in the next Feder. Reg. 
[ 300 ] 
