THE UNIVERSITY OF NORTH CAROLINA 
AT 
CHAPEL HILL 
Division of Health Affairs 
The School of Medicine 
Department of Bacteriology and Immunology 
The University of North Carolina at Chapel Hill 
804 Faculty Laboratory Office Building 231 H 
Chapel Hill, N.C. 27514 
August 24, 1979 
Director, Office of Recombinant DNA Activities 
Bldg. 31, Room 4A52 
National Institutes of Health 
Bethesda, MD 20205 
Dear Sir: 
I would like to offer my comments in support of item 1 (44 FR 45088) 
1. Proposed Exemption of E. coli K-12 Host-Vector systems. 
I have written several times to this office concerning the Federal 
Guidelines on REcombinant DNA Research. My arguments have been that 
the guidelines in general represent an unwarranted excursion into the 
freedoms of inquiry. This is based on the premise that the burden 
of proof must lie, in the absence of consensus, with those that 
argue that a hazard exists. Since no consensus exists and no 
evidence for hazard has been established it follows that there 
should be no mandatory guidelines. 
The proposal above seems reasonable to me in that it is based and 
justified on documentation of lack of hazard instead of colorful 
conjecture. While this appears to be a novel approach in the guide- 
lines it should be heartily encouraged. I wish to add my support 
to this step in the right direction. 
Sincerely 
Marshall Hall Edgell 
Professor 
MHE/jb 
f312] 
