PUBLIC AND SCTENTinC AFFAIRS BOARD 
AMERICAN SOCIETY FOR MICROBIOLOGY 
1913 1 Stmet. N.W. 
Washinoton, D. C 20006 
Teleehonb: Code 202. 833-9680 
12 January 1982 
Dr. William J. Gartland 
Director, Office of Recombinant DNA Activities 
Building 31, Room 4AS2 
National Institutes of Health 
Bethesda, Maryland 2020S 
Dear Dr. Gartland: 
The Public and Sclantlflc Affairs Board (PSAB) of tha American Society 
for Microbiology (ASM) would Ilka to submit the following comments on 
the proposed revisions of the NIH Guidelines for Research on Recom- 
binant DNA which will be considered at the Recombinant DNA Advisory 
Committee meeting on February 8, 1982. 
The Public and Scientific Affairs Board of ASM believes that there Is 
need to streamline the guidelines for work with recombinant DNA. The 
present guidelines are cumbersome. In part overly restrictive, and do 
not take Into account all the available Information. We believe that 
simplifying them will result In greater use of safe procedures, and 
therefore. In greater safeguard of both microbiological workers, the 
community and the environment. 
The debate in recent years has centered on the question of whether or 
not the Introduction of foreign DNA Into a host cell can result In an 
organism of greater pathogenicity than either the donor or the recipient. 
In other words. Is the whole more dangerous than the sum of the parts? 
In the case of well characterised recipients, such as Escherichia coll . 
strain K-12, the answer Is almost certainly no. Therefore, proper safety 
procedures for using such organisms are those that pertain to the donor 
of the recombined DNA. Proper procedures are not specific to recombinant 
DNA work but pertain to pathogenic agents In general. The key element 
In this consideration Is that a considerable amount of Information Is 
available about Escherichia coll K-12 and a few other host organisms. 
Our concern Is for the fact that only sparse Information Is available 
for other host-vectors. With less characterized systems, new combin- 
ations may result In organisms of potentially Increased pathogenicity 
than either the donor or the recipient. Thus, the Introduction of genes 
for toxins of low potency In recipients that can colonize man, animals 
or plants, could result In potentially dangerous organisms. Analogous 
arguments can be made for certain drug resistance traits. On the other 
hand, we believe that, for a variety of reasons, risks are mainly to the 
[ 659 ] 
