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EMORY UNIVERSITY SCHOOL OF MEDICINE 
DEPARTMENT OF MICROBIOLOGY AND IMMUNOLOGY 
502 Woodruff Memorial Building 
Atlanta, Georgia 30322 
January 5, 1982 
Dr. William J. Gartland, Jr. 
Director, Office of Recombinant DNA Activities 
Department of Health and Human Services 
Public Health Service 
National Institutes of Health 
Bethesda, Maryland 20205 
Dear Dr. Cart land: 
I am In favor of Annex C, completely abolishing the Guidelines, 
or, falling that, of the revision of the recombinant DNA guidelines 
proposed by RAC (Dec. 4, Federal Register) - which make adherence 
voluntary. The Initial purpose of these guidelines was to make 
Investigators conscious of potential hazards and appropriate con- 
tainment. I believe that purpose has been effectively served. 
Since the Initial promulgation of the guidelines, experiments 
have provided safety data that Is reassuring and It seems appro- 
priate at this time to relax the guidelines with this In mind. 
The guidelines were supposed to be an Interim arrangement until 
data was available. It la now, and they should be eliminated. 
I have two specific comnents to make which stem from my personal 
Interes ts. 
It has always seemed odd to me that the current system 
forces the Investigator wishing to work with a bacterial pathogen 
whose genetics has not been studied much to first demonstrate 
that It can exchange genes with a suitable cloning host before 
cloning can proceed. Surely the preliminary In vivo experiment Is 
at least as dangerous as the cloning experiment. These guidelines 
must certainly be delaying Important research on pathogens. 
I have a further concern about cloning of genes that are 
toxic for vertebrates since I believe the posture of the guidelines 
on this to be Illogical. If an investigator wishes to work with 
a highly potent toxin having a very low U) 3 o, the Investigator Is 
certainly aware of the hazards and will take adequate precautions 
when handling the toxin. I submit that these are easier and 
therefore that such experiments are safer when the organism pro- 
ducing the toxin can be grown In a small volume. Cloning the toxin 
gene would permit this. For this reason, I believe It Is actually 
safer to work with such toxins when their genes are cloned. Further- 
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