MASSACHUSETTS INSTITUTE OF TECHNOLOGY 
77 MASSACHUSETTS AVENUE 
GAMBRIDCF... MASSACHUSETTS 02139 
DEPARTMENT OF BIOLOGY 
16-531 
PHONE: (617) 253-1000 
September 22, 1978 
Mr. Joseph Callfano 
Secretary, 
Department of Health Education & Welfare 
Washington, D.C. 20460 
Dear Mr. Callfano: 
Reaping the potential benefits of recombinant DNA technology clearly 
depends on the ability to contain the potential public health hazards. I 
find no substantial evidence or argument presented in the draft revised 
guidelines or supporting documents to justify the major weakening of contain- 
ment proposed therein. I am particularly concerned over the lowering of 
containment for shotgun experiments with DNA from birds and mammals; the 
lowering of containment for cloning eukaryotic viral DNA; and the transfer 
of authority for lowering guidelines from the NIH to local, nonrepresentative, 
nonexpert, part-time committees, an extraordinary transfer of public federal 
functions to private bodies. 
The draft Guidelines and supporting documents, though representing 
considerable labor and effort, are marred by four major fallings; 
A) The absence of the most relevant, observations which form the 
basis for the need for containment in the first place. 
B) A major logical fallacy, pervading the entire set of documents, 
in which the ability to perform a set of experiments safely, is • 
confused with the safety of the materials themselves. 
C) Heavy reliance on unreferred, unpublished, unexamined reports 
of small appointed committees, meeting in private, in complete 
contradiction to the canons of scientific process, and governmental 
process. 
D) Extraordinary selectivity in quotation, in which no arguments or 
data which lead to a tightening of the guidelines are presented 
nor referred to. 
[A-295] 
