NORTHWESTERN UNIVERSITY 
EVANSTON, ILLINOIS 6OT01 
DEPARTMENT OF BIOLOGICAL SC1ENCBS 
September 25, 1978 
Dr. Donald Frederickson 
Director 
National Institutes of Health 
Bethesda, Md. 20014 
Dear Dr. Frederickson: 
We are writing to encourage you to approve the proposed Guidelines for Recombinant DNA 
Research as published in the Federal Register vol. 42 no. 187, September 27, 1977. 
The three of us are young scientists who have recently set up our own laboratories. 
We work independently, but we share a common interest in the organization and 
regulation of genes in higher cells, and we all use recombinant DNA procedures in our 
research. 
The proposed revisions of the Guidelines will reduce to the P-2 level of containment, 
micro-organisms containing DNA from non-primate animal cells. Since two of us work 
with vertebrate DNAs, the Guidelines will affect us directly. The argument can be 
made that, even in the absence of demonstrated hazard from organisms containing 
recombinant DNA, the prudent step is to retain stringent containment as an added 
precaution, and as an example of scientific responsibility. We would like to argue, 
on the other hand, that the retention of P-3 containment conditions for non-primate 
DNA will serve as a major impediment to research by young investigators like ourselves. 
The cost of implementation of P-2 containment is not extreme. We now have a limited 
access room with all necessary equipment which we have had renovated and furnished 
with funds at our disposal. The total cost for this research facility was about 
$10,000. The cost of a P-3 facility is, by our standards, staggeringly high; in 
excess of $50,000. This amount of money for renovation is seldom available to young 
scientists. The result is that work at Northwestern on DNA from vertebrates, except 
for work on a few characterized clones, will stop. Experimentation of this sort will 
become concentrated in institutions with large laboratories headed by more established 
scientists. Other individuals who are now graduate students or post-docs with 
interests in recombinant DNA research will then be encouraged to remain in such large 
laboratories, rather than starting out on their own, professionally and intellectually. 
We do not feel that it is necessary or wise to remove all restrictions on recombinant 
DNA research. However, the Guidelines as now exist are unrealistically stringent. The 
proposed revisions seem to us to be a well considered and timely compromise. We 
urge your approval 
Yours sincerely 
Jeffrey L. Doering 
Assistant Professor 
Biological Sciences 
J. Douglas Engel 
Assistant Professor 
Biological Sciences 
Assistant Professor 
Biochemistry and 
Molecular Biology 
