Center for Health Sden^ 
University of Wisconsin-Madison 
Department of Physiological Chemistry 
1215 Linden Drive 
589 Medical Sciences Building 
Madison, Wisconsin 53706 
Telephone: (608) 262-1347 
■ December 23, 1980 
Director 
Office of Recombinant DNA Activities 
Building 31, Room 4A52 
National Institutes of Health 
Bethesda, Maryland 20203 
Dear Colleagues: 
It has been called to my attention that the notices in the Federal 
Register, Vol. 45, No. 231 of November 28, 1980, include a proposal by Dr. 
Winston Brill that the Guidelines be amended to permit the use of PI contain- 
ment conditions for experiments involving non-pa thogenic prokaryotes and lower 
eukaryotes . 
I would like to state my support for this proposal, and urge that it be 
adopted. The need for higher levels of containment adds appreciably to the 
difficulty and cost of doing experiments and unnecessarily hampers progress in 
this important field. 
Let me say that I think this proposal is timely - neither premature, nor 
past due. I was one of the "go slow" people when recombinant DNA work first 
emerged because I felt that a development of such great sweep and power might 
also have serious unforeseen possibilities for accident or mischief. I felt 
that we could afford to be very careful until there was more experience under 
our belt. This experience is now amply on hand, and any apprehensions I had 
have been put to rest. 
A few developments have been especially reassuring. It now seems that 
the only thing revolutionary about recombinant DNA technology is to be able to 
make it happen at a time (now) and place (test tube) of our choosing; nature 
has in all likelihood been doing it for ages. Second, I have been impressed 
at how unlikely it is for an organism carrying foreign DNA to prosper in 
competition with highly attuned, wild organisms of the same species. (A 
friend of mine likens foreign DNA to a carburetor on a washing machine). My 
own experience is that I must keep my plasmLd-carrying strains under selective 
pressure with antibiotics or they are outgrown by spontaneous variants which 
have lost the plasmid. Others tell me that they can quite reliably distinguish 
bacterial colonies carrying recombinant DNA plasmids from those carrying non- 
recombinant plasmids because recombinant colonies are considerably smaller due 
to their slower cell division. Finally, we now have more than five years of 
actual working with recombinant DNA in which no manipulated organism seems to 
have established itself at any time in the human, in domestic animals or 
plants, or in the wild. 
[557] 
