Page 2 
Ray Thornton, J.D. 
February 1, 1982 
than from other types of research. We should continue, I believe, to be 
responsibly conservative in these matters. The Gottesman proposal does Just 
that. It would not be obstructive to the conduct of recombinant DNA research 
In these -areas. 
There are other areas of risk to be considered as well. The question of 
surveillance of large-volume experiments Is one that needs further discussion 
before discarding It as Insignificant. The deliberate misuse of recombinant 
DNA technologies for defensive or offensive reasons Is a "scare scenario” that 
was discussed and discarded early In the debate. But recent trends In civil 
defense require reconsideration of such possibilities and the possible 
usefulness of mandatory guidelines In this context. 
I believe we should continue to have a responsible process for guiding 
recombinant DNA research without undue restrictions. We should strive to 
reduce the complexity of the task while retaining the mechanism that has 
worked well so far. Since the problems have not all been resolved, this would 
be reassuring to the public and to the Congress, as well as scientifically 
valid. 
The fundamental Issue is to retain, until more is known, the guidelines 
and a process that responds to new Information by appropriate revisions. 
In the face of the enormous Intensification of publicity about the 
possibilities for monetary rewards from recombinant DNA research, major abrupt 
change In the guidelines would appear to be an abandonment of all safeguards 
in the rush for commercial exploitation. This may be an unfair but plausible 
criticism. 
My recommendation Is to have a limited period of more relaxed regulations 
by supporting the Gottesman proposal now and immediately work to simplify the 
guidelines further as appropriate. Specific areas for further simplification 
can be discussed at the next meeting. Several come easily to mind. 
The Gottesman proposal Is a responsible next step in the process that 
started at Asllomar. 
P.S. Our correspondence of last fall Is attached. Were notices of the 
proposed actions published? 
Enclosure 
cc: RAC Members 
William Gartland, Jr. ‘ 
Sincerely 
Elena 0. Nightingale, M.D., Ph.D. 
Senior Program Officer 
[ 760 ] 
