Residential College 
East Quadrangle 
The University of Michigan 
Ann Arbor, Michigan 48109 
(313) 763-0176 
Auc-ust 22, 1979 
To: Dr. Donald Fredrickson, Director, NIH 
From: Dr. Susan Wright 
Re: Proposed Supplement to the NIH Guidelines for Recombinant 
DNA Research, Federal Register , Vol.44, No. 151. Friday, 
August 3, 1978 (extension of the guidelines on a voluntary 
basis to industry). 
This proposal Is Ill-advised for the following reasons: 
1. "Voluntary compliance" means that the private sector will obey 
the guidelines when it is in its Interests to do so and not other- 
wise. However, one of the assumptions behind the assignment of 
levels of containment to recombinant DNA experiments is that all 
practitioners will use them. It makes no sense for a researcher 
funded by NIH to obey the guidelines if his/her colleague, carrying 
out the same procedures in a private laboratory close by, does not. 
The situation also clearly places academic scientists at a dis- 
advantage . 
2. The history of attempts at voluntary control of hazardous processes 
by the private sector provides little basis for believing in the 
effectiveness of voluntary compliance. Indeed it has often been 
industrial failure to anticipate hazards, and the disasters that have 
occurred as a result, that have brought about action in Congress 
and regulatory controls. 
When Paul Berg and others called for a partial suspension of work 
in the recombinant DNA field in 1974, there was a strong feeling that 
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