Or. Donald S. Fredrickson, Director 
- 2 - 
November 7, 1977 
I strongly urge you to adopt this second solution, since there is no reason 
to hamper very beneficial research employing many important organisms for which 
no practical hazards could be logically conceived, juSt because of a few 
Isolated cases where some scary scenarios could be Imagined. Let's include 
these few isolated cases (as specificed above under (1) to (3)) under the 
Guidelines and exclude from the Guidelines all other E_. coll K- 1 2 EKl and EK2 
hosfvector-based experiments. 
One requirement could be instituted for these latter experiments: to 
register them with the N.I.H. and local Safety Committees on one-page forms 
specifying (l) name and address of ail investigators, (2) cloned DNA, (3) 
host-vector system [k) physical containment, (5) purpose of the experiments, 
and (6) dates covered by the registration. Such registration would have to 
be filed concurrently with the initiation of the experiments, but no specific 
approvals would be required. 
The reasons I urge you to institute this change in the proposed Guidelines 
are at least twofold: 
(1) There is no logical justification to control the great majority of 
safe and beneficial experiments on the basis of "guilt by association" with a 
few questionable experiments arbitrarily placed in the same class (see Hogness' 
letter and the P.S.). It is better to treat the questionable experiments 
separately, by including them in the Guidelines. 
(2) The Guidelines seriously interfere with many experiments, and a few 
latest examples of that are represented by letters of Or. R. Palmiter (study of 
purified chicken ovalbumin gene), S. Cohen (study of dihydrofolate reductase) and 
8. W. O'Halley (characterized clones of ovalbumin ONA) reviewed at the November 1, 
1977 meeting of the Advisory Committee. No dangers could even be imagined for the 
proposed experiments, but nevertheless they will be seriously delayed or blocked. 
Moreover, there is a useless expenditure of taxpayer's money and the loss of time 
by the investigators, N.I.H. , and the Committee on preparing applications, processing 
and considering them, where there is no logical need for all these bureaucratic 
evaluation procedures. 
I sincerely hope that'the present golden opportunity will not be lost to 
exclude from the regulations all the novel recombinant ONA experiments where no 
practical dangers could be even imagined (cloning of Saccharomyces yeast ONA, 
Drosophi la fly ONA, ONA of laboratory animals like mice or rats, specific 
human DNA) , whereas the scientific and social benefits are great. Otherwise, 
history will cast us in the position of Colonel Nicholson defending 'The Bridge 
on the River Kwai" or of courtiers in the Hans Christian Andersen story about 
"The Emperor's New Clothes". 
With the warmest personal regards, 
/ 
t icarely yours, ^ 
Waclaw Szybalski \ 
Professor of Oncology 
WS :mb 
[Appendix A — 47] 
