EMEO 
EUROPEAN MOLECULAR BIOLOGY ORGANIZATION 
Executive Secretary. Dr. John Tooze 
EMC Egwwx aougr OgraMx 
lop 40 o-moD i 
Postfach 1022.40 
6900 Heidelberg 1 
Federal Republic of Germany 
Or. William J. Gartland Jr. 
Director, Office of Recombinant 
DNA Activities 
National Institutes of Health 
Building 31, Room 4A52 
Bethesda, Hd 20205 
USA 
13 January 1982 
Dear Bill , 
1 an replying to your letter of December 18, 1981 in which you 
invite coranents on proposals for a major revision of the National 
Institutes of Health Guidelines for Research Involving Recombinant 
DNA molecules. 
In my opinion, the proposal published in the Federal Register of 
December 4, 1981 should be adopted. There seems to me to be no valid 
reason for mandatory regulation via guidelines of recombinant DNA 
research since there is no evidence that this activity is intrinsically 
hazardous. It is clear that anyone working with known dangerous organ- 
isms should take the necessary precautions mandated for those organisms 
but there is no reason for mandatory regulation of recombinant DNA work 
per se. A voluntary code of practice should be adequate and would, I 
believe, be respected. 
That the guidelines desperately require simplification is self 
evident to anyone who tries to read and understand them. Finally, 
there is, I believe, no case for specific prohibitions because work 
with organisms that are Included in the prohibitions is already covered 
by regulations etc. relating to the handling of dangerous organisms. 
Since very many European countries either use the NIH guidelines or 
closely model national guidelines on them any decision taken by the NIH will 
have far reaching repercussions. I believe it is time to have the courage 
of our convictions and vote to convert the guidelines into a purely volun- 
tary code of practice. This would endanger nothing, facilitate research 
and save a great deal of money. 
Best regards 
John Tooze 
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