MEMORANDUM 
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE 
PUBLIC HEALTH SERVICE 
NATIONAL INSTITUTES OF HEALTH 
NATIONAL CANCER INSTITUTE 
TO Dr. William Cart land DATE: November l, 1977 
PROM Maxine Singer 
SUBJECT: Comments on Che Draft Version of Che Revised NIH Guidelines for Recombinant 
DNA Research, 6/23/77 
Section I Introduction 
Page I-i : First paragraph, last sentence. While I understand the 
purpose of the sentence Co indicate one set of cases that are not novel, 
there is a little ambiguity. Thus, it will not usually be true Chat the 
"genomes" are known to replicace within an organism, rather, Chat 
seccions or parts of Che genomes may do so. A strict constructionist 
might have unnecessary trouble with this. 
Foocnote 1: Since Che Introduction makes it clear chat nothing is 
"not novel" until it is listed, it 3eems to me that the primary effect of 
this footnote is to remove flexibility even given Che Words "in general" 
at Che start. I would suggest omitting the foocnote. 
Section II Containment 
Page II-5, (7)... there appears to be a typo. 
Page 11-32, a. second sentence: "Natural environment" could be 
ambiguous, in practice. Presumable many of the host cells that people 
may wish to use have no natural environment other chan the laboratory. 
Section III Experimental Guidelines 
Page III-2, item ii: Would footnote'^ be appropriate here? Note 
Chat there is an apparent paradox between this prohibition and the specific 
containment recommendations for experiments possibly involving chance pro- 
duction of recombinants containing genes for "pocent toxin". I understand 
that the word "deliberate" is meant to make Che necessary distinction, 
but wonder if it might be a little clearer. 
Page III-4, a.(l)(a): Does this include tissue culture cells as a 
source of DNA, and if so, does it include transformed cells containing 
viral genomss? la the situation different if Che viral genome just happens 
to be there but is not tha object of Che cloning? And how about guidance 
for cloning tha viral genomes themselves from such sourcas. Do chess 
recommendations hold or thoae for virusas (page 111-9/ or ones similar Co 
[Appendix A — 29] 
