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NEWELL W. ELLISON 
JOHN O. LAYLIN 
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FONTAINE C. BRADLEY 
EDWARD BURLING, JR. 
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OF COUNSEL 
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CABLE* COVLINO 
October 26, 1978 
Donald S. Fredrickson, M.D. 
Director 
National Institutes of Health 
Building 1, Room 124 
9000 Rockville Pike 
Bethesda, Maryland 20014 
Dear Don: 
On two earlier occasions I have reviewed proposed 
guidelines for recombinant DNA research and have provided 
my comments on them. Further revisions were proposed in the 
existing guidelines in the Federal Register on July 28, 1978 
(43 F.R. 33042). Regrettably, I left for vacation just as 
they were released and have not had an opportunity to study 
them since my return until this past weekend. Although I am 
aware that the time for public comment has expired, I am 
nonetheless submitting these brief comments in the hope that 
they may be useful to you. If their lateness precludes your 
consideration of them I will understand completely. 
My two earlier letters considered the legal and con- 
ceptual bases for the regulation of recombinant DNA research. 
There is no need for me to reiterate those comments except 
again to emphasize that any regulation of research should re- 
main flexible and never become static. As more information 
demonstrating the safety of this research becomes available, 
the guidelines should be revised accordingly until, hopefully, 
some day the need for regulation may disappear completely. 
In general, I believe the latest proposal is a faith- 
ful reflection of the consensus of views stated at the last 
[A-443] 
