Boston University Medical Center 
School of Medicine 
80 East Concord Street 
Boston, Massachusetts 02118 
Department of Socio-Medical Sciences September 22, 1978 
and Community Medicine 
Dr. Donald S. Fredrickson, Director 
National Institutes of Health 
9000 Rockville Pike 
Bethesda , MD. 20014 
Dear Dr. Fredrickson: 
In response to your call for public comment on the Proposed 
revisions of the NIH guidelines for Recombinant DNA research, 
published in the Federal Register on July 28, 1978, I would like 
to offer the following observations. I have confined myself to 
the areas where I have most expertise, but I note here that there 
are other important issues, such as the generic designations in 
the exempt list of "exchangers", which are glaring defects given 
our present state of knowledge. 
It is my conviction that the proposed revisions, like their 
predecessors, will contribute nothing to another of the gaps in 
our current knowledge, and this prompts these comments. I am 
speaking of the possible risks to human health and well-being 
that are posed by Recombinant DNA research, and their detection 
if they should be realized. My comments cover two areas: (1) 
The assurance of safe procedures in Recombinant DNA laboratory 
work; (2) the detection of untoward events should these procedures 
fail. 
[A-248] 
