INTERNATIONA!. PAPER COMPANY 
TUXEDO PARK, N.V. 10©07. PHONE 91A 331-2101 
CORPORATE RAO DIVISION 
November 21, 1977 
Director 
National Institutes of Health 
9000 Rockville Pike 
Bethesda, Maryland 20014 
Dear Sir: 
At present, the NIH Guidelines for Recombinant DNA Research do 
not apply to privately funded research on this subject, but proposed 
legislation indicates that these guidelines may become the basis 
for future regulation. Even though these Guidelines do not presently 
govern activities in our laboratories, it is not our intent to 
initiate efforts that might be considered irresponsible, and we 
desire to keep any efforts we might initiate within the limits 
imposed by these Guidelines so that the disruption of our programs 
by pending regulation can be minimized. 
In general, my response to proposed revision is favorable. 
The emphasis is understandably focused on operational systems in 
bacteria and mammalian cells. Our interest is on host-vector 
systems by which recombinant DNA techniques can be extended to 
plants. To the best of my knowledge, no such systems are available. 
My purpose in writing is neither to endorse nor denounce any par- 
ticular provision in the proposed revision, but to raise certain 
questions regarding intent and interpretation. 
Novel Recombinant DNAs . If one assumes that recombinant DNA 
formed from species of plants capable of producing viable inter- 
specific hybrids (i.e. different species known to exchange chromo- 
somal DNA by natural physiological processes) are not novel recombinant 
DNAs, meaningful efforts in development of host-vector systems 
employing plant organelle genomes as vectors can be initiated with 
materials not regulated under the proposed revisions. Furthermore, 
if recombinant DNAs formed from plant viruses and DNA from plants 
with which the viral host can hybridize are propagated in normal 
viral host Ci.e., all components are derived from genomes known to 
replicate within the organism used to propagate the recombinant 
DNA) are not considered to be novel recombinant DNAs, the use of 
plant viruses as vectors can be investigated using materials not 
regulated by the proposed revision of the Guidelines. These two 
[Appendix A — 78] 
