3 . 
in the present Guidelines resulted from insufficient knowledge and 
incomplete reasoning. It is indeed difficult to imagine how a cloned virus 
genome would be more dangerous than the original virus itself. Many of us 
worked for years with eucaryotic viruses in laboratory situations without 
special precautions and without apparent harm. While common sense dictates 
the use of good technique in the handling of all virus material, there is no 
apparent justification for continuing the ban on the cloning of virus 
genomes except where specific risks are indicated. Similar reasoning 
applies to the use of viruses as vectors for the introduction of foreign 
DNAs in eucaryotic cells. Clearly these techniques make possible or 
practical many experiments which promise to yield considerable information 
on the organization and regulation of gene expression in eucaryotic systems. 
I have one basic criticism of both the present Guidelines and the 
proposed revisions. This criticism is not concerned with safety afforded to 
the public by the provisions contained within the Guidelines, but deals with 
the administration of the Guidelines. The present Guidelines were created 
by the NIH and ultimate responsibility for those Guidelines resides in the 
hands of the Director of the NIH. However, the NIH Guidelines effectively 
apply to all government-sponsored recombinant DNA research, not just to NIH- 
funded projects. For the Guidelines to be meaningful it is essential that 
they apply to all research, but in essence, the present Guidelines give the 
Director of NIH a monopoly on recombinant DNA research. I anticipate that 
recombinant DNA technology will become increasing important in non-health 
related research, in agriculture, in energy and in industry. Thus it would 
seem reasonable that the responsibilities for regulating recombinant DNA 
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