-7- 
The entire document is concerned with the comparison of viral disease 
with viral-like disease from an _E. coli containing viral sequences. But 
the report falls to deal with the problem of generating increased bacterial 
pathogencity from viral sequences. Is it really impossible to conceive that 
bacteria containg in their envelopes the viral proteins that permit viruses 
to attach to mammalian cells, might not have increased host range, colonizing 
ability, or pathogencity? 
D) Selective Quotation. 
The documents continually present only one side of the argument. 
Gorbach's letter on unlikelihood of converting K12 into an epidemic pathogen 
is continously referred to, without discussion of the fact that there was 
major concern of transfer of chimeric plasmids to wild strains of £. coli . 
There is no reference to the recent paper showing that EK2 strains cause 
death in healthy mice when administered intercranially , interper itoneally , 
or intravenously. (Levy, Sullivan and Gorbach, 1978). 
Just one example of many, many such biased presentations; On page 
33123 the Environmental Impact Assessment deals with the likelihood of 
transfer of DNA from coli K12 to wild strains by naturally occuring lambda 
bacteriophage. Since much of the cloning is done with lambda vectors, using 
cells sensitive to lambda phage, and containing lambda sequences, this is 
a serious possibility. According to the document "It (lambda) is considered 
very unlikely to survive and to infect resident j£. coli in animals and 
humans, being highly sensitive to stomach acid, reluctant to infect smooth 
E. coli cells (the type normally found in the gut) and susceptible to drying, 
as would occur if it escaped into air". Later two personal communcations 
are referred to in support of this general position. Thus we are to believe 
that lambda bacteriophage which was originally isolated from nature; and 
coll K12, the host from which lambda was originally isolated from, are 
unlikely ever to find each other in the natural environment! Perhaps lambda 
doesn't survive in the human gut. What about sewers, urinary tracts, soil, 
and chicken guts, all friendly habitats for E^. coli . 
In conclusion, the proposed revisions of the guidelines are premature. 
They are not based on data or positions gathered under the normal canons of 
scientific investigation, modeling, and verification. 
The benefits of recombinant DNA technology can be reaped perfectly 
efficiently under the existing guidelines. Neither pressure from commercial 
enterprises interested in exploiting the technology, nor over-eager scientists 
involved in the excitement of research, should be allowed to unduly influence 
the RAC. Their primary responsibility just be the protection of public and 
environmental health. The current proposed revisions are a step backwards 
from that responsibility. 
Sincerely your 
snathan King 
(ssociate Professor of Biology 
JK:mcp 
see references on 
following page 
[A-301] 
