August 11, 1977 
TO: Coalition for Responsible Genetic Research 
FRO#: t. Douglas DeNike Ph. D. , 2677 Rllendale Place, 
Los Angeles, CA 90007 (213) 733-9307 
RE: Deflating the Curtiss letter 
A widely-circulated 13-page letter has recently had a "big impact'* in support 
of the idea that recombinant-ENA hazards have been overestimated ( Science. 22 July 
1977, p, 3ii8). The letter was written April 12 by Roy Curtiss III of the University 
of Alabama, Birmingham, to NIH Director Donald S. Fredrickson, Its author by no means 
asserts that recombinant DNA work is free of biohazards. He merely argues that stan- 
dard "EK1" microbial strains are sufficiently safe if all other precautions are 
observed. Since erroneous secondhand interpretations of Curtiss's views may weaken 
pending Congressional legislation, or its subsequent enforcement, this memorandum of 
clarification is offered. 
Here is Curtiss's main conclusion (letter, p, 9): "In view of all the accumulating 
information discussed above (without any literature references!), I have gradually come 
to the realization that the introduction of foreign OJA sequences into SO. and EK2 host- 
vectors offers no danger whatsoever to any human being with the exception already men- 
tioned that an extremely careless worker might under unique situations cause harm to 
him- or herself." He does not intend to offer any general assurances regarding con- 
jugative plasmids in wild-type 5. coll . or wild-type phage, or anything beyond. 
Curtiss and his colleagues labored for many months to develop the less-viable 
EK? "^1776" (chi 1776) E, coll strain to provide an additional safety factor in 
recombinant DNA experiments. But ^1776 is described as "...a very poor grower, is 
inconvenient to use, and requires constant monitoring to verify its many biological 
properties" (R. Novick, Bulletin of the Atomic Scientists. May 1977, p. 20), By 
implication, Curtiss argues that The field need not be saddled with the inconvenience 
of jl776 or other specially crippled bugs. 
However, Curtiss ends up supporting legislation to make the NIH safety Guidelines 
("or sane slight ^modification thereof") mandatory for all individuals using recombinant 
ENA molecules for whatever purpose, whether in the public or private sector (letter, 
p. 12). In short, he acknowledges genuine risks. For instance, on p. 11 he says it 
would be "rather stupid and unlikely" for research with wild E, coll and other enteric 
pathogens to be done in the same lab used for recombinant ENA work. 
Since he recognizes that here may be real dangers, it is puzzling that Curtiss 
opposes licensing of laboratories and/or scientists, and opposes inspections save 
for Ph facilities (letter, p. 12). He wants to leave the policing largely up to 
"hard-working and conscientious" institutional biohazards committeea—but he presents 
no evidence that such committees will in fact adequately watch over their peers. 
This, of course, reflects the fact that no experimentation has ever been done to test 
empirically the real-life efficacy of the^biohazards-coirenittee system in supervising 
recombinant IMA. safety standards. Despite the obvious need and the hundreds of 
scientists involved in the field, not one has sought to find out Just how well local 
in-house overseers detect and correct deficiencies in prescribed equipment, materials, 
and procedures. This gaping hols in the "scientific" armor of the research gives the 
citizen little reason to feel confident. The expert once of microbiology isn't terribly 
relevant since different hasarde and training standards are involved, 
[Appendix A — 19] 
