THE UNIVERSITY OF ARIZONA 
HEALTH SCIENCES CENTER 
TUCSON, ARIZONA 85724 
COLLEGE OF MEDICINE 
UNIVERSITY DEPARTMENT OF BIOCHEMISTRY 
(602) 626-6025 
September 18, 1978 
Dr. Donald Fredrickson 
Director 
National Institutes of Health 
Bethesda, Maryland 20016 
Dear Dr. Fredrickson: 
I have read a copy of the Proposed Revised Guidelines for 
Recombinant DNA Research (Federal Register 43, 33042-33178) . 
I agree with the general nature of the proposed changes. The 
two major factors which make these changes valid are a) the 
general inability of eukaryotic genes to be expressed in pro- 
karyotic cells and b) the inability of fL coli K-12 to effectively 
colonize the human gut. 
There are, however, two inconsistencies which I noticed in 
the proposed changes to the guidelines. These are the conditions 
required for cloning mammalian DNA (other than primates) and bird 
DNA in a shotgun experiment. The guidelines state this should be 
performed under P2-EK2 conditions. I believe it should be changed 
to P2-EK2 or P3-EK1 . The concept of allowing the biological 
containment to be reduced when the physical containment is 
increased has numerous examples in the guidelines. Specifically 
the combination of P2-EK2 .or P3-EK1 containment is found for 
experiments 6, 12, 13, 19, 25, 42 and 43 (pg. 33133 to 33135 of 
the proposed revisions to the guidelines) . It seems an oversight 
that a similar combination of containment is not allowed for birds 
and mammalian (non-primate) shotgun experiments. 
Sincerely yours 
Larry A. McReynolds 
LAM/ cs 
[A-170] 
