Dr. Donald S. Fredrickson 
- 2 - 
August 29, 1978 
3. The Guidelines have become an extremely complex legal document, the 
complexity of which bears no relationship to the hypothetical risks 
they are supposed to control. The damage caused by the Guidelines 
greatly outweighs their benefits, if any. This damage created by 
the regulations includes (1) creating novel or aggravating existing 
hazards, (2) political dangers, (3) depleting and misdirecting valuable 
resources, (**) fostering bureaucracy, (5) denying or delaying benefits 
to society, and (6) misdirecting environmental concerns and other 
beneficial measures, as described in the enclosed article (W. Szybalski, 
Dangers of Regulating the Recombinant DNA Technique, Trends in Biochemical 
Sciences , November 1978). 
It is also clearly stated by your Deputy Director Dr. DeWitt Stetten 
(published in Gene 3_, 1978, pp. 265~268) "that regulation is antithetical 
to creativity , and ... that the best regulation for the flowering of 
science is the least regulation..." I also concur with his proposal 
that the NIH Guidel ines should be replaced by a very simple statement, 
e.g., "The conditions of containment appropriate for any recombinant 
DNA experiment are those which are dictated by the most virulent or 
dangerous organism entering into that experiment". 
I strongly Implore you to start prompt action leading to abolishing the 
unnecessary, bureaucratic and complex Guidelines and replacing them with some 
simple (one sentence or one paragraph) statement indicating that any recombinant 
DNA activities involving use of pathogenic organisms should be done with proper 
precautions and prudence. The time Is ripe for such action and I am sure that 
your forsight and courage will lead to a successful conclusion of this rather 
Infamous chapter in the history of the biomedical sciences. 
With the warmest personal regards, 
WS : k j d 
[A-60] 
