STANFORD UNIVERSITY MEDICAL CENTER 
STANFORD, CALIFORNIA 94305 
DEPARTMENT OF BIOCHEMISTRY Area Code 415 
Stanford University School of Medicine 497-6161 
September 15, 1978 
Dr. DonaldS. Fredrickson 
Director 
National Institutes of Health 
Building 1, Room 124 
Bethesda, Maryland 20014 
Dear Dr. Fredrickson: 
I am writing in reference to the Proposed Revised Guidelines 
for recombinant DNA research. In general, I would anticipate that 
the proposed guidelines will be a marked improvement over the pre- 
sent obsolete and inadequate guidelines. However, I have the following 
objections to the proposed revisions. 
1. The new PI and P2 containment conditions are not significantly 
different. The difference between PI and P2 should be approximately 
the same as the difference between HV1 and HV2, and this is clearly 
not the case. I think that there is a need for a low level physical con- 
tainment for those organisms considered of minimal risk. 
2. I object strongly to the escalation of the PI and P2 containment 
rules. They should be made more stringent only if there is a demon- 
strated inadequacy in the present rules; I know of no such inadequa- 
cy. Unwarranted changes such as this one make administering a 
research laboratory much more difficult. And in addition, as a teacher, 
I am at a loss to explain to students and colleagues the need for the 
changes. 
3. In section U-B-2-9-(l6), the sentence "The laboratory shall be 
kept neat and clean. " is totally ambiguous and should be dropped. 
Having a statement such as "Common sense shall be used in the labora- 
tory. " would be more useful. 
4. The use of biohazard signs at the P2 level should be discontinued, 
they should be reserved for demonstrated biological hazards. There is 
a real danger that overuse of these signs in cases where workers know 
they do not apply will lead to the ignorning of all biohazard signs. A 
possible compromise might be to have universal "Hypothetical Bio- 
hazard" and "Real Biohazard" signs of different color and design. 
[A-159] 
