UNIVERSITY OF WASHINGTON 
SEATTLE, WASHINGTON 98195 
Program in Social Management of Technology 
18 December 1979 
Dr. Donald Fredrickson 
Director 
National Institutes of Health 
Bethesda, MD 20205 
Dear Dr. Fredrickson: 
I am responding briefly to the November 30 Federal Register notice regarding 
proposed revisions to the DNA Guideline. 
1) I urge you to extend the comment period. Given the delay in receipt of 
this Document, and the holiday season, there is not appropriate time for a 
sufficient analyses and response by interested persons such as myself. 
Please notify me particularly if you do so, and I will attempt to supplement 
these observations. 
2) I will re-iterate my concerns about reducing containment levels to 
EK,/P, in section III of the November 30 notice which I expressed in my letter 
to you dated October 8, 1979 (which I hereby wish to incorporate by reference). 
I continue to be disturbed that such far-reaching policy changes are being 
considered in the absence of data from a risk assessment program . I appreciate 
that it is difficult -- legally and scientifically both -- to prove a negative 
(i.e. the "absence" of risk, or more accurately, that a risk does not rise 
above certain levels deemed "safe"), but certainly the best operating procedure 
would be to first have an experimental protocol, carry out the experiments, 
subject the results to comment and criticism, and then relax safety guidelines 
if justified. I believe the pressures from research scientists to reduce safety 
precautions first and then do the assessment of risks is unjustified and 
irresponsible. Particularly with the existence of some evidence that certain 
E-col i risks may be considerably different from what we have been led to 
expect (I refer to Dr. Stuart Levy's findings regarding the vitality of 
Chi 1776), we should not rush ahead in this fashion. 
Therefore, I urge you not to promulgate the Revisions of November 30, 1979. 
Very truly yours, 
Phillip L. Bereano $f- 
Associate Professor 
PLBrsf 
314 Guggenheim, FS-13 / Telephone: (206) 343-7029 
[ 532 ] 
