MEMORANDUM DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE 
PUBLIC HEALTH SERVICE 
NATIONAL INSTITUTES OF HEALTH 
NATIONAL CANCER INSTITUTE 
TO : Director, NIH DATE: August 18, 1978 
FROM : Chief, Laboratory of Biochemistry DCBD, NCI 
SUBJECT: Proposed Revised Guidelines for Recombinant DNA Research 
1. I have read the Proposed Revised Guidelines for Recombinant DNA Research 
carefully and with great interest. I believe that a remarkably good job has 
been done in the revision process and that if approved, the new Guidelines 
will be far superior to the old ones. 
2. I would like to disagree with the second paragraph of Section IH-A-l-a, 
which addresses the question of whether one should be allowed to replace 
P2+EK.2 with P 3+EK1 . Such replacement has been specifically interdicted in 
the case of DNA from birds. I believe that such replacement should be allow- 
ed in the case of avian DNA. I am currently engaged in recombinant DNA ex- 
periments utilizing shotgun techniques for inserting chicken DNA fragments 
into bacterial phages and plasmids, utilizing EK2 host-vector systems and the 
P3 level of containment. The birds we work with are highly inbred, are main- 
tained on feed that is free of antibiotics, nitrofurans, arsenicals, and all 
pesticides currently assayed by the FDA, and have been shown by the appropri- 
ate testing procedures to be free from Pollorum typhoid , Mycoplasma gallisep- 
tlcum , Mycoplasma snyoziae , Salmonella typhimurlum , and avian leukosis virus. 
I do not see any reason for requiring an EK2 system for our experiments car- 
ried out in a P3 facility 
3. Another suggestion 1 would like to make concerns the details of the P3 
level of containment. I believe that it would be wise to require that boot- 
ies must be worn at all times within the P3 lab, just as gowns must be worn. 
It seems to me that the force of gravity tends to make the floor the most 
likely place for any contaminating substance to end up, not only in the case 
of an accidental spill of gross proportions. Since shoes are an ideal me- 
chanism for carrying material into and out of rooms, I think they should be 
covered. I have, in fact, instituted an absolute rule that booties must be 
worn in my P3 facility and I suggest that this procedure be made part of the 
guidelines requirements. 
[A-25] 
