THE MILTON S. HERSHEY MEDICAL CENTER 
THE PENNSYLVANIA STATE UNIVERSITY 
DEPARTMENT OF MICROBIOLOGY 
HERSHEY, PENNSYLVANIA 17033 
717 534-8253 
October 17, 1977 
Donald S. Fredrickson, M.D. 
Director 
Department of Health, Education and Welfare 
Public Health Service 
National Institutes of Health 
Bethesda, Maryland 20014 
Dear Dr. Fredrickson: 
I respond to your note dated October 8, 1977 with the attached 
draft of revised guidelines for recombinant DNA research. In general, I 
find the draft an excellent one but wish to make the following comments: 
1. Safety is still based primarily on containment. Though training 
in aseptic technique is mentioned, this is clearly not the focus of the 
guidelines. Yet it probably represents the key to safety. How will 
this be evaluated? Containment facilities can be checked but no provision 
is made to determine the level of training of the principal investigator 
and his personnel (it may be as important to train the janitor and 
glassware washer as the scientist). Any "break" in technique will 
destroy physical containment procedures. 
2. In V. Footnotes (49605) under number 5 (paragraph 2), it is 
categorically stated that "genes coding for the synthesis of virus 
capsid components have not been associated with oncogenesis". This is 
true for the adenoviruses and papovaviruses . It is not correct for the 
herpesviruses. Cells transformed by Epstein-Barr , herpes simplex and 
cytomegaloviruses contain genes for structural proteins. The "early" 
regions of herpesvirus DNA code for structural proteins. Thus, proteins 
found at the membrane of transformed cells contain virus structural 
components . 
3. Amazingly, appendix B makes no reference to herpes simplex or 
cytomegalovirus presumably because these viruses have not yet been shown 
[Appendix A — 15] 
