THE JOHNS HOPKINS UNIVERSITY 
SCHOOL OF MEDICINE 
DEPARTMENT OF MICROBIOLOGY 
725 N. WOLFE STREET 
BALTIMORE, MARYLAND 21205 
December 26, 1979 
Dr. Donald Fredrickson, Director 
National Institutes of Health 
Bethesda, Maryland 20205 
Dear Dr. Fredrickson: 
I write to urge adoption of the proposed revisions of the Recombinant 
DNA Research Guidelines published in the November 30 Federal Register. We 
now have several years experience with both recombinant DNA experiments 
and the Guidelines. Recombinant DNA research has provided astounding 
breakthroughs in our understanding of the genetic structure of higher 
organisms and of the basis of plasticity in immune response. These basic 
results, along with applied experiments by W. Rowe, M. Martin and others 
have demonstrated the safety of eukaryotic genes in bacterial hosts. 
Experience with the guidelines has been much more negative. Not only 
have millions of dollars been wasted building unnecessary containment facili- 
ties, but many thousands of hours (and research dollars) have been wasted 
learning to cope with the required bacterial strains. A greater, unmeasurable 
cost has been the loss of simple creative experiments which after being 
forced through the guidelines become "not worth the trouble". 
The cost of the limits on experiments in Eh coli in dollars, time and 
creativity cannot be justified by either the imagined spectre of danger or 
the necessity for public accountability. 
Adoption of the revised guidelines, and section III-O p. 69218 in particular, 
would be a cost effective addition to the NIH budget and our basic understanding 
of a range of biomedical problems. 
Sincerely 
William R. Pearson, Ph.D 
Research Fellow 
WRP :mk 
[ 594 ] 
