UNIVERSITY OF OREGON 
HEALTH SCIENCES CENTER 
DE PA RTMENT OF BIOCHEMIS TR Y 
SCHOOL OF MEDICI HE 
Area Code 503 225-7781 
Portland, Oregon 97201 
December 12, 1979 
Dr. Donald Frederlckson 
Director, NIH 
Bethesda, Maryland 20205 
Dear Dr. Frederlckson: 
I am writing to support the new proposed guidelines for regulating 
recombinant DNA research which appeared In the Federal Register for 
Friday, November 30, pp 69210-69251. Although I have not engaged In 
such research, I am concerned, as are many others, with the potential 
hazards of such activities, and I am also excited about their potential 
benefits. As a molecular biologist, I am roughly familiar with the 
field and with some of the methodology Involved. (I got my Ph. D. In 
Paul Doty's lab at Harvard in 1958). As safety committee chairman In 
a medical research building, I have had experience with the manner in 
which research scientists react to the promulgation and enforcement 
of safety regulations. 
I believe that it is Impossible to regulate recombinant DNA research 
via strict "OSHA-type" legislation unless we can obtain the full and 
enthusiastic cooperation of the "regulatees" l.e., the scientists who 
are performing the research. If the regulatees can be convinced that 
the potential hazards really exist, this should be easy, as they will 
be on the "front lines" and will be most likely to be adversely 
effected by nasty recombinant bugs which might be produced. However, 
If the regulatees are skeptical about the dangers, they will resist 
regulation. This will be especially the case if they feel that a lot 
of "senseless, bureaucratic red tape" Is hindering their search for a 
cure for cancer or a solution to the energy crisis whereas researchers 
in other countries with less stringent rules are less encumbered. 
Government Inspectors will be seen as "busy bodies" and outwitting 
them will become a game. Unfortunately, It will be a game In which 
the researchers have all the marbles. 
Thus, it would be very easy for a researcher to make a potentially 
hazardous experiment seem harmless by misrepresenting the nature of 
the materials he was using. For example, he might put a label saying 
"E. coll DNA" on a bottle which really contained human DNA, Whereas . 
the introduction of E. coll DNA into E. coll bacteria is .harmless, 1 
similar Introduction of human DNA Into such bacteria ^^potentially 
C Li'kiVl fv *7* 
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