MASSACHUSETTS INSTITUTE OF TECHNOLOGY 
CENTER FOR CANCER RESEARCH 
77 MASSACHUSETTS AVENUE, CAMBRIDGE, MASSACHUSETTS 02139 
November 28, 1979 
Secretary Patricia Harris 
Department of Health, Education and Welfare 
Washington, D.C. 
Dear Secretary Harris: 
It has recently come to ray attention that you have requested 
another thirty day public comment period on the newest proposed re- 
visions to the NIH Guidelines for Research Involving Recombinant DNA 
Molecules. As a member of the Recombinant DNA Advisory Committee 
(RAC) and as a scientist who has been involved in the controversies 
about recombinant DNA, I find your request for a further comment 
period both arbitary and pointless. 
The original proposal which led to these new revisions first 
came before RAC last spring. It was considered by a subcommittee 
over a three month period and was then voted upon by RAC. It was 
supported by an overwhelming majority. The decision of the Committee 
was taken after an appropriate period for public comment and was made 
after careful consideration of available risk assessment data. This 
procedure fulfilled all of the requirements for modification of the 
Guidelines as specified in the Guidelines. To consider this matter 
further is a waste of time of the Committee. More importantly, by 
not acting to modify the Guidelines, you are forcing scientists to 
use containment procedures that RAC has already determined are un- 
necessarily burdensome. 
Although the development and revision of the Guidelines for 
recombinant DNA research has been a long, frustrating and extremely 
time-consuming operation, the scientific community has participated 
in it out of respect for public process. When that process becomes 
arbitrary and totally unsympathetic to the goals of the scientific 
community then the respect of scientists for public process is cer- 
tain to deteriorate. I realize that having set into motion this thirty 
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