MEMORIAL SLOAN-KETTERING GANGER CENTER 
1275 YORK AVENUE. NEW YORK. NEW YORK 10021 
September 27, 1978 
Dr. Donald S. Fredrickson 
D1 rector 
National Institute of Health 
Bethesda, MD 20014 
Dear Dr. Frederickson : 
I would like to express niy support of your attempt to revise the NIH 
Guidelines for Recombinant DNA Research. I am using recombinant DNA techniques 
to study immunoglobulin genes in the mouse. I have read the Proposed Revised 
Guidelines (Federal Register 43(146), 33042-33178), and find them more rational 
than the extant Guidelines. Tor example, they recognize that in many cases it 
is safer to work with viral DNAs in the form of recombinant DNA than as a virus 
particle or as viral DNA. I agree with your statements that the years of 
experience with recombinant DNA have shown that the likelihood of a dangerous 
organism being produced is extremely low; and that the burden of proof should 
be shifted to those who would claim the experiments are dangerous. It is also 
true that as we learn more about the genomes of eukaryotes, we are learning how 
difficult (impossible?) it would be for a prokaryote to translate a eukaryote 
gene. 
We have already experienced a tremendous Increase in the pace of research 
in molecular biology due to cloning techniques. These Proposed Guidelines will 
help greatly in this respect, especially in the field of virology. The Proposed 
Guidelines will make it easier to use recombinant DNA techniques, and therefore, 
will help research progress more rapidly. I believe this will have great benefits 
to humankind in the fields of health and agricu 1 ture. 
I also believe that the NIH has done a commendable job of regulating 
recombinant DNA research. You have gathered together tremendous expertise in 
making your studies and decisions. I think it is reasonable for NIH to determine 
safety procedures for research because it has this expertise available to it. 
However, it Is still very cumbersome to operate within these regulations because 
of the large bureaucracy involved. The Proposed Guidelines have done much to 
correct this by allowing us to apply to our local IBCs for the minor decisions. 
However, if Congress were to legislate the Guidelines, the bureaucracy would 
probably Increase, and I expect changes in procedures would be even more difficult 
to implement. (Furthermore, Congress should have much more important things to 
do). If individual states were to legislate, the situation would be even worse, 
because it is very improbable that they would gather the necessary expertise. 
However, I do have a criticism of the Proposed Guidelines. I believe they 
are too strict given the apparent lack of dangers in these experiments. For 
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MEMORIAL HOSPITAL FOR CANCER AND ALLIED DISEASES 
SLOAN-KETTERING INSTITUTE FOR CANCER RESEARCH 
SLOAN-KETTERING DIVISION. GRADUATE SCHOOL OF MEDICAL SCIENCES. CORNELL UNIVERSITY 
