STANFORD UNIVERSITY MEDICAL CENTER 
STANFORD, CALIFORNIA !) 4}05 
DEPARTMENT OF BIOCHEMISTRY Area Co.lt 413 
Stanford L'xivEtim School of Memclne 497 GIGI 
November 2, 1977 
Dr. Donald Fredrickson 
Director 
National Institutes of Health 
Bethesda, Maryland 20014 
Dear Dr. Fredrickson: 
The following are my comments on the new proposed NIH guide- 
lines for recombinant DNA research. 
1) Use of IT/ designation . I am happy to see this essential change. 
2) DNA containment, page 49603(5) . This section is a disaster, 
and if it remains in the guidelines, it could undermine their credibility. 
DNA is not an organism , it is a chemical . Handling a chemical by 
"good microbiological technique" is absolutely ridiculous. 
a) It is assumed in these guidelines that the reason recombinant 
DNA may be potentially hazardous is that such recombinants cannot 
be generated by "natural" means. From present experimental evidence 
we know that if DNA can enter cells, recombinant DNA 3 are readily 
generated. Therefore, if DNA can naturally enter cells, then recom- 
binant DNA cannot be hazardous. If DNA Cannot naturally enter cells, 
then again the DNA cannot be hazardous. 
b) Dead organisms contain DNA. I find it absurd to think that a 
live organism containing recombinant DNA that is handled at the PI 
and P2 levels must also be handled at the PI level after it is dead. 
c) One of the major containment techniques i3 to kill the organisms 
early in the course of an experiment and to then extract their DNA. 
Under the new guidelines, this containment technique would have to be 
abandoned as ineffective. I think this is wrong. 
d) Autoclaving DNA poses grave health hazards to research per- 
sonnel Iprobably far greater than any live organism containing recom- 
binant DNA). For example, most DNA samples that are to be disposed 
of contain ethidium bromide and ^2p Contamination of autoclaves 
with these materials could be quite dangerous. 
[Appendix A — 31] 
