The Joseph and Rose Kennedy 
Georgetown University 
institute of Ethics 
Washington, D.C. 20057 
Center for Bioethics 
202/625-2371 
Donald S. Fredrickson, M.D. 
Director 
National Institutes of Health 
Building One, Room 137 
Bethesda , MD 20014 
Dear Dr. Fredrickson: 
November 1, 1979 
I am writing in response to published charges that improper procedures 
were followed by the Recombinant DNA Advisory Committee at its September 
meeting. The allegations concern the Committee's approval of reduced 
physical containment levels and revised oversight procedures for most 
types of research involving Eh_ coli K-12 host-vector systems. 
Improprieties alleged, in particular, by a New Scientist article 
("Dirty Tricks in Genetic Engineering Committee?" New Scientist , 4 October 
1979, p. 3) include the following: 
1. The Recombinant Advisory Committee (RAC) made its 
decision hastily. 
2. The agenda of the meeting was changed, and the vote 
on this issue was moved ahead. 
3. Scientists and industry officials teamed up to force 
the proposed change in guidelines through the Committee. 
4. Non-scientists on the Committee did not understand the 
issues at stake. 
5. Only 10 of the 25 RAC members voted in favor of the 
proposed changes in guidelines. 
Of these allegations, the first, third, and fourth are demonstrably 
false. The second is true but reflects only a desire by the Chairperson 
to accomodate a Working Group of the Committee. And the fifth is true 
but entirely appropriate according to well-established procedures for 
Federal advisory committees. In the following paragraphs I will comment 
on each of the allegations in turn. 
1. Few decisions by the RAC have been made so deliberately and 
carefully as the recommendation to reduce physical containment levels 
and revise oversight procedures for research involving coli K-12 hosts 
and vectors. The original Rowe-Martin proposal to exempt most coli 
K-12 research was published in the Federal Register on April 13, 1979, 
discussed at length at the May RAC meeting and studied by a Working Group 
containing persons holding various views on the issue. A revised proposal 
was published in the Federal Register on July 31, 1979, commented on by 
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