THE 
UNIVERSITY 
OF UTAH 
5C126 MEDICAL CENTER 
SALT LAKE CITY. UTAH 84132 
801-581-8777 
COLLEGE OF MEDICINE 
DEPARTMENT OF 
MICROBIOLOGY 
August 12, 1978 
Dr. Donald S. Fredrickson, Director 
National Institutes of Health 
Bethesda, Maryland 20014 
Dear Dr. Fredrickson: 
Thank you for sending me a copy of the new Proposed Revised 
Guidlines governing recombinant DNA research and for your invitation 
to comment on them. I am very much in sympathy with the thinking 
which has dictated a reduction in most of the containment levels. 
Both our hazard-free experience over the past 5 years and general 
considerations of microbial ecology suggest greater confidence that 
the real dangers connected with recombinant DNA work are minimal. 
In addition, the very sensible exclusions from jurisdiction of the 
Guidelines eliminate many absurd restrictions which exist, largely 
due to oversight, in the current regulations - e.g., the prohibition 
on cloning Salmonella or Salmonella phage DNA in Salmonella , the use 
of E. coli strains other than K-12 as hosts of E. col i T ool i phage 
recombinant DNAs and the handling of purified DNAs outside host 
organisms. I am in complete agreement with your request that we 
should continue to be sensitive to the consequences of the practice 
of recombinant DNA research. Direct experiments testing potential 
hazards should also help to determine whether the Guidlines need to 
be tightened or can be relaxed further. 
As you note, flexibility is an important component of the regu- 
lation of recombinant DNA research. Retention of final authority 
for designating containment levels in your office, as opposed to 
solidifying the designations in federal legislation, seems most sensible 
Placement of executive authority for determining compliance with the 
regulations at the institutional level, particularly with the Institu- 
tional Biosafety Committee, represents a major improvement over the 
present Guidlines. Currently, a great deal of time and effori is lost 
in abundant correspondence between individual investigators and a 
distant and sluggish dureaucracy. 
[A- 10] 
