CALIFORNIA INSTITUTE OF TECHNOLOGY 
PASADENA. CALIFORNIA 91125 
DIVISION OF BIOLOGY 156-20 
January 3, 1980 
Dr. Frederickson 
The Director 
National Institutes of Health 
Bethesda, Maryland 20205 
Dear Dr. Frederickson: 
I am writing in support of the proposed revisions of the NIH Guidelines 
regarding recombinant DNA research which involves the use of the host EL coli 
K12. My comments address the question of the requirement for submitting a 
Memorandum of Understanding (MUA) to the NIH and the physical containment 
requirements for such experiments (Federal Register Vol. U4 , No. 232, Nov. 30, 
1979 ) . 
First, I feel that the provision which eliminates the requirement for 
submitting MUA's and registering experiments with the NIH will lead to a 
more efficient and rapid application of recombinant DNA technology to biomedical 
research. The existing requirement for NIH approval of all recombinant DNA 
experiments has led to frustrating and unnecessary delays caused by the 
inability of the NIH to cope with the enormous amount of paper work resulting 
from the registration requirement. A great deal of effort was made by the 
recombinant DNA advisory committee to institute properly constituted local 
biohazard committees (IBC). Why not take advantage of these duely constituted 
committees? All of the MUA's covering the experiments using E_. coli K12 as 
host are simply statements of compliance with NIH requirements for physical 
and biological containment. The primary function of the IBC is to make 
certain that the proposed experiments are in fact in compliance with the 
Guidelines. At the present time this function is duplicated by the require- 
ment for submitting MUA's to the NIH. 
Second, it is ny opinion that the information summarized in your comments 
on the "E. coli K12/P1 recommendation" (Section 3, pages 69235-692U6) fully 
Justify the proposed revisions. The information compiled during the past 
few years regarding the lack of infectivity and potential pathogenicity of 
E. coli K12 with or without recombinant DNA clearly argue that concerns 
regarding the dangers of this research can no longer be rationally supported. 
Sincerely yours , 
Tom Maniatis 
Professor of Molecular Biology 
Hi : s c 
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