THE UPJOHN COMPANY 
KALAMAZOO. MICHIGAN 49001. USA 
September 22, 1978 
GENERAL LAW 
Office of 
MURRAY D WELCH. JR 
Associate General Counsel 
and Director 
TELEPHONE (61 6) 323-6068 
Dr. Donald Fredrickson 
Director, National Institutes of Health 
Bethesda, Maryland 20014 
Dear Dr. Fredrickson: 
"Proposed Revised Guidelines" for recombinant DNA research were 
published in the Federal Register for July 28, 1978.1 The Upjohn 
Company supports these Guidelines . While we believe that they are 
both reasonable and appropriate, we have a few suggestions which, 
in our opinion, would improve the Guidelines. They are: 
1 . I-E-3. Amend this section to read : 
I-E-3. Those that consist entirely of DNA from a prokaryotic 
host, including its indigenous plasmids or viruses, when propa- 
gated only in that host [ (or closely related strain of the same 
species)] or another organism in the same genus ; also those 
that consist entirely of DNA from a eukaryotic host, including 
its chloroplasts , mitochondria, or plasmids (but excluding 
viruses) , when propagated only in that host (or a closely re- 
lated strain of the same species) . 
Note: Omitted language is in [brackets]; new language is 
underlined . Hereafter, this format will be used. 
Justification 
Under the Proposed Revised Guidelines, many experiments involv- 
ing the insertion of recombinant DNA derived from a non-pathogenic 
prokaryote into another closely related non-pathogenic prokaryote 
will not be permitted even under P-4 physical containment . Pro- 
hibition o7 these types of experiments will severely limit the 
The Guidelines would apply if the institution receives NIH funds 
for recombinant DNA research projects (The Upjohn Company receives 
no such funds). Ref. IV-C-1, pg. 33087; or, if the institution 
voluntarily registers with NIH, Ref. IV-C-2, pg. 33087. 
[A-256] 
