CARNEGIE INSTITUTION OF WASHINGTON 
Department of Embryology 
115 West University Parkway 
Baltimore. Maryland 21210 
TELEPHONE: 467-1414 
September 18, 1978 
Dr. Frederickson, 
The Director 
National Institutes of Health 
Bethesda, Md. 20014 
Re: Proposed revised guidelines for recombinant DNA research 
Dear Dr. Frederickson, 
I wish to comment briefly on the revised NIH Guidelines elaborating 
on some of the remarks that I made in my public testimony on September 15. 
On the whole the revisions are a good step toward a more rational set of 
procedures, the existing guidelines being unnecessarily strict. 
1. There is no reason not to make all shot gun experiments P2 EK1 
and to permit the cloning of viruses and viral fragments. We simply must 
admit that these pieces of DNA in E_. col i cannot be more dangerous than 
their original source. This statement has irrefutable logic as an 
assessment of potential risk. 
2. It is logical and sensible to give much authority to local biohazard 
conmittees. The rules are set forth in such detail that there can be very 
little worry about uneven interpretation by different committees. The 
burden on the NIH committee seems overwhelming at present. I agree that 
individuals who work with recombinant DNA should not be members of these 
committees. However it is rediculous to populate a committee designed to 
control biohazards with lay people having no understanding of the issues. 
The members should include knowledgeable microbiologists, epidemiologists, 
public health specialists and yes, biochemistry and even molecular biologists. 
3. Case by case analysis of experiments following outside the guidelines 
is welcome although it means more burden for NIH. 
(Conintued -- page 2.) 
[A-164] 
