UNIVERSITY OF CALIFORNIA, SAN FRANCISCO 
BERKELEY • DAVIS • IRVINE • LOS ANCELES • RIVERSIDE • SAN’ DIECO • SAN FRANCISCO 
SANTA BARBARA • SANTA CRUZ 
SCHOOL OF MEDICINE 
DEPARTMENT OF BIOCHEMISTRY AND BIOPHYSICS 
December 14, 1979 
SAN FRANCISCO. CALIFORNIA 94143 
(415) 666-4324 
Howard M . Goodman 
Dept. Biochem./Biophys. 
University of California 
San Francisco, CA 94143 
Dr. Donald Fredrickson 
Director of the N.I.H 
Bethesda , MD 20205 
Dear Dr. Fredrickson: 
I wish to support the proposed revisions of the recombinant DNA 
guidelines as described in the Federal Register for Friday, November 
30, 1979, pp. 69210-69251, and particularly section III-O. All available 
evidence indicates that potential danger from any recombinant DNA experi- 
ment is vanishing small and hence the decision to allow experiments 
using £. coli K12 host-vector systems to be carried out at the PI con- 
tainment level (except for exempt and prohibited experiments) is entirely 
appropriate. 
My personal opinion is that the data does not even warrant regis- 
tration of these experiments. To my knowledge and from my own experience 
of working five years in the field of genetic engineering there has not 
been a single case of disease or any other form of bodily harm attributable 
to recombinant DNA experiments. Also, our direct experience with expression 
of hormone genes in coli K12 would indicate that the prior approval by 
the IBC of such experiments is not necessary. 
In conclusion, 
lines even though I 
I strongly support the proposed revisions to the guide- 
believe them to still be far too stringent. 
Sincerely yours, 
Howard M. Goodman, Ph.D. 
Professor 
