STANFORD UNIVERSITY MEDICAL CENTER 
STANFORD, CALIFORNIA 94505 
DEPARTMENT OF BIOCHEMISTRY Area Code 415 
STANroao UNrvxwTTY School or Medicine 497-6161 
April 22, 1981 
Dr. Villiaa Gartland, Head 
Office of Recoabinant DNA 
NIGHS, Bldg. 31 4AS2 
Betheada, HD 20205 
Dear Bill, 
I aa writing to you regarding the proposed changes in The Guide- 
lines for Recoabinant DNA Research put forward by Drs. Baltimore and 
Campbell that appeared in the Federal Register of Friday, March 20, 1981 
on pages 17994-7 (Vol. 46 #54). As I understand their recommendation it 
is 1) to convert the current NIH Guidelines for Recombinant DNA Research 
from mandatory regulations (for virtually all university and institute 
scientists) to a non-aandated, but recommended code of standard prac- 
tices and 2) to reduce the recommended containsient levels for certain 
experiments . 
Lest there be any doubt about ay views on this let me be quite 
direct. I strongly favor their suggestion and have done so for some 
time. Indeed, in a letter to Dave Baltimore of July 2, 1980, I said "I 
find it increasingly difficult to accept the maintenance of a non- 
trivial govemaient bureaucracy to contend with the mythical possibility 
that recombinant DNA experimentation is hazardous. After all we have not 
imposed the same requirements on virus research or other 'potential 
hazardous* laboratory activities. In those instances, society and the 
government have accepted individual and institutional assurances for 
safe practices and culpability for negligence or deliberate violations. 
RAC has elected a strategy for evolutionary change in The Guidelines, 
but in my view, it has not been without paying a substantial price: the 
time and energy of ORDA, RAC members, institutional committee members 
and the scientists doing the research, as well as the expenditures to 
maintain ORDA, ORDA, RAC and the new layers of bureaucracy that have 
been spatmed in the imiversities . I do believe it is time to seriously 
consider whether the ORDA-RAC format should continue .... I would 
favor its dissolution and replacement by something like the advisories 
put out by CDC in the field of pathogenic microorganisms and tumor virus 
research; that is, an effective and a relatively simple classification 
and advisory for handling pathogenic or potentially pathogenic organisms 
and viruses. Didn't that kind of advice serve us well for tumor viruses 
before recombinant DNA"? 
[591] 
