22 Kensington Drive 
Manalapan, lew Jersey 07726 
September 10, 1978 
Offioe of the Director 
lational Institutes of Health 
Be the s da, Maryland 20014 
Dear Dr. Fredriokson* 
In referenoe to an article in the July 28, 1978 issue of the Federal Register 
entitled Reoonbinant DHA. Research Proposed Guidelines, I have inclosed sons 
subjective oonments. 
Superficially, the proposed revised guidelines for reoonbinant OTA research 
appear politically and eoononioally aooeptablet However, guidelines based 
on the assumption that S. ooli K^g cannot inadvertently beoome pathogenic 
are, at best, unscientific (ref. to page 53160 of the Federal Register 28 July, 
"Cloning Viral DBA's in S. ooli K]^)* * fell to oomprehend how the participants 
at the Falmouth meeting "were unable to envisage a sequence of events which 
could ooour with significant probability that would allow E. ooli carrying 
either whole OTA genome of oertain viruses or subgenomio fragments of virtually 
any virus to lead to disease." Perhaps the following flow sheet could be of 
some value in designing a three pronged experiment to test suoh probability. 
[A-96] 
