Appendix B 
the University of Alabama in Birmingham / university station / Birmingham, alabama 35294 
the Aledical ^?d7//cv'/ DEPAR ™ ENT 0F microbiology / July 18, 1978 
Dr. John Spizizen 
Department of Cellular Biology 
Scripps Clinic and Research Foundation 
La Jolla, California 92037 
and 
Dr. Donald Hel inski 
Department of Biology 
University of California, San Diego 
La Jolla, California 92093 
Dear John and Don: 
I am writing in response to your letter of July 10th concerning Appendix A to 
the Guidelines for Recombinant DNA Research. The proposed Appendix A to the 
NIH Guidelines as presently written is not acceptable to me. One can adopt 
either a liberal or a conservative position in deciding what organisms to list 
and in what groupings but with either approach, one must be consistent. I find 
fault with the proposed Appendix A since it is not consistent and it is also 
incomplete. Such inconsistency and incompleteness will raise havoc in the 
scientific community and utter confusion on the part of those charged with 
interpreting the Guidelines and enforcing the regulations associated therewith. 
In order to illustrate the various perspectives one can take on Appendix A, I 
will enumerate some principles (conservative or liberal) and give some examples. 
I should indicate at the outset that I am not recommending one or the other 
approach but rather that one should be consistent and in doing so one can amass 
appropriate literature citations to support the particular stance taken. 
The Conservative Position 
In Appendix A, include groupings of those species in which stable inheritance of 
expressed chromosomal genes by genetic recombination and/or by gene pickup on a 
plasmid has been demonstrated . 
Examples 
List 1. Pseudomonas aeruginosa into Escherichia coli . This type of transfer 
with stable inheritance of expressed chromosomal genes has been demonstrated to 
occur and thus justifies the cloning of any and all DNA from Psuedomonas 
aeruginosa strains into Escherichia coli strains. The reciprocal cloning of 
E_. coli DNA into strains of Pseudomonas aeruginosa would not be permitted if one 
AN AFFIRMATIVE ACTION / EOUAL OPPORTUNITY EMPLOYER 
[A-319] 
