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THE JOHNS HOPKINS UNIVERSITY 
SCHOOL OF MEDICINE 
DEPAKTMENT OP 
MOLBCULAt B101X)GY AND GENETICS 
725 N. WOLFE STREET 
BALTIMORE. MARYLAND 21205 
January 5, 1982 
Dr. Wllllaffl J. Gartland, Jr. 
Director 
Office of Recoablnant IXIA Activities 
National Institutes of Health 
Building 31, Boon 4A52 
Bethesda, MD 20205 
Dear Dr. Gartland: 
I an responding to your memorandum of 18 December Inviting 
cooaents on revision of the NIH Guidelines for Research Involving 
Recombinant DNA. After careful reading of the proposal by the RAC and 
that by Dr. Susan Gottesman, I strongly support the RAC proposal for 
making the guidelines voluntary and eliminating excessive 
administrative oversight. As I have argued on several prior occasions. 
It makes no sense to have more stringent requirements for research that 
carries only vague hypothetical risks than for experiments Involving 
known pathogenic microbes. Voluntary guidelines have worked quite well 
for reaearch Involving pathogens and should work equally well for 
microbes containing recombinant DNA. Under voluntary guidelines the 
responsibility Is with the Individual Investigator and his Institution, 
as It should be. After several years of experience It Is time to 
recognize that there Is no scientific or social justification for 
retaining rules for recosiblnant DNA research that Inhibit creativity 
and waste resources. 
Professor and Director 
Department of Molecular 
Biology and Genetics 
