STANFORD UNIVERSITY 
STANFORD. CALIFORNIA 94303 
department of biological sciences December 11, 1979 
Dr. Donald Fredrickson 
Director, National Institutes of Health 
Bethesda, Maryland 20205 
Dear Dr. Fredrickson: 
At the December RAC meeting, Jane Setlow announced that you would like to 
hear the opinions of RAC members about the E^. coll K-12/P1 motion. 
As one of the authors of the motion, I can only say that I consider it an action 
that is long overdue. Two or three years ago, it was perhaps defensible to 
maintain that recombinant DNA research was so new that it might pose unexpected 
dangers. As David Botstein's letter in the last RAC folder implies, there 
really never were any expected dangers. Despite that fact, there was some 
logic to the idea of going slowly just in case there were some surprises. By 
this time, extensive experience has failed to reveal any unusual properties of 
artificial recombinants, and no one has formalized a plausible theory that 
predicts any hazards. If cloning in K-12 were not already under the Guidelines, 
I doubt that anyone could provide a reasonable justification for treating it 
as sufficiently extraordinary to require the procedures now in force. There 
is something completely out of proportion with a system that imposes more 
stringent regulation on a bacterium harboring a random fragment of yeast DNA 
than it does on a bacterium known to cause cholera or diphtheria. Only the 
inertia of some rather unwieldy political machinery keeps these regulations 
in force. 
Because of this inertia, whatever respect the scientific community may once 
have had for the NIH Guidelines is rapidly deteriorating. At the present pace 
of technology, I fear that the situation will get worse before it gets better. 
RAC is already being confronted with many developments that were unanticipated 
when the 1978 Guidelines were drafted, and with many experiments that were 
essentially prohibited by default at that time, because no one wanted to do 
them anyway. If RAC has any constructive role to play, it will be to review 
new developments as they occur and to take prompt, reasonable action to ensure 
that research proceeds under appropriate conditions of safety. The only hope 
of achieving that goal is to get out of the way all the time-consuming chores 
of administering obsolete and superfluous rules. It is disheartening to find 
that, even after thorough consideration and approval by RAC, the j£. coli K-12/P1 
measure remains in administrative limbo. 
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