THE UNIVERSITY OF ROCHESTER 
MEDICAL CENTER 
601 ELMWOOD AVENUE 
ROCHESTER, NEW YORK 14642 
AREA CODE 716 
SCHOOL OF MEDICINE AND DENTISTRY • SCHOOL OF NURSING 
STRONG MEMORIAL HOSPITAL 
DEPARTMENT OF MICROBIOLOGY 
Frank E. Young, M.D., Ph.D. 
Professor and Chairman 
275-3407 
September 14, 1978 
Dr. Donald S. Fredrickson 
National Institutes of Health. 
Immediate Office of the Director 
Building 1; Room 124 
Bethesda, Maryland 20014 
Dear Dr. Fredrickson: 
I wish to compliment you, your staff at NIH, and the recombinant 
DNA Advisory Committee for the excellent job that you did on the pro- 
posed revised guidelines which were published Friday, July 28, 1978. 
This detailed analysis represents a great deal of work and I’m sure no 
small effort on your own part. I am in essential agreement with, most of 
the revisions but I wish to raise a few additional points for your 
consideration and evaluation. 
1. ) I'm in wholehearted agreement with, your prohibition of mouth, 
pipeting in recombinant DNA laboratories. . This is an important advance 
and should be applied to all levels of research, 
2. ) I concur with your exemptions 2, 3 and 4 but have some reservation 
in regards to the first exemption. There are not any data to my knowledge 
that deal with the inactivation of DNA in nature that has been thoroughly 
reviewed and critiqued. For instance, does closed circular DNA inactivate 
at a different rate than double stranded or single stranded DNA? Is the 
rate of inactivation different depending on what the DNA is bound to, 
for example soil versus laboratory surfaces? Could the DNA bind to the 
surface of a microbe and be released in the form of a passenger? Without 
these questions answered it may be less prudent to exempt inactivation 
of DNA at this time. The inactivation of DNA is relatively simple and 
it might be prudent to preserve such, a precaution. 
3. ) I wholeheartedly support the definition of recombinant DNA 
research and the provisions for physical containment. I only wonder 
whether more specific guidelines should be developed regarding the 
accessibility of the autoclave In the P-2 facility. If the building is 
large it may not be sufficient to merely have an autoclave for sterilization 
of waste within the same building, particularly if one has to use stairs 
or elevators to find the autoclave. You may also wish, to reevaluate the 
discretionary use of laboratory gowns within the laboratory. It seems 
less prudent to not wear laboratory coats in a microbiology laboratory. 
[A-150] 
