T estimony of W. Szybalski at the Meeting of the Advisory Committee to the 
Director, N.I.H. (December 1 5~ 1 6 , 1377). 
Dr. Fredrickson, Members of the Advisory Ccmnittee: 
My name is Waclaw Szybalski. I am a Professor of Oncology, University of 
V/isconsin Medical School. For three years I was a member of the Advisory 
Committee on Recombinant DNA, at the time that the present and the new 
proposed Guidelines were drafted. I am not carrying on any research which 
involves novel recombinant DMA. 
1. We are gathered here because in 197*+ several scientists were voicing 
concerns about the possibility of serious epidemics caused by E_. col i K-12 
carrying recombinant DNA. 
2. At present, in December 1 977 , we know "that £. col i K-12 cannot be 
converted into an epidemic pathogen by laboratory manipulations with DNA 
inserts", and there is uniform agreement about it among well-informed 
experts in the field of epidemiology and medical microbiology (see 
Memo NAR- 89 /I in NARSM, May 15“July 15, 1977). This conclusion agrees 
completely with the experimental facts and with all that we know about the 
mechanisms of epidemics. 
3. If the scientists who sounded the 197*+ warning had been informed as well 
as we are now, no letter to "Science" would have been written, there would 
not have been any N.I.H. Guidelines for Recombinant DNA Research, and we 
would not have been here today. 
*t. So what should we do now with those parts of the Guidelines which are to 
protect us from imaginary dangers that we know are of no practical concern? 
5. The Recombinant DNA Advisory Committee, of which I was a member, acted as 
Committees usually do, i.e., it acted conservatively in a politically cautious 
way, it took time, it worked hard and tried not to "rock the boat". The 
Committee took the following actions: 
(a) Combinations of DNA from those organisms which frequently 
recombine in nature were eliminated from the Guidelines. This 
was a wise and positive action, but not original, since it 
followed the legislative proposals of the U. S. Congress. 
(b) slight adjustments in the prescribed containments were made, 
(c) and most unusual, a new introduction was prepared stating that 
the "Guidelines continue to be deliberately restrictive with the 
intent of erring" on the side of caution (Federal Register, 
Sept. 27, 1977 p. *+9597, column 1, the end of the third paragraph). 
6. So how shall we comment on this new version of the "deliberately restrictive" 
Guidelines, still so much out of tune with the present assessment of the 
hypothetical risks as to be intentionally erroneous? 
7. Let me make one major suggestion, which would render the Guidelines 
scientifically more sound, but still quite conservative. I suggest that 
with only a few exceptions, one should exclude from the Guidelines all 
experiments employing EKl or EK2 host-vector combinations which carry novel 
recombinant DNA. If you think it would be helpful, you should require only 
a very simple registration of these EKl or EK2 experiments. E_. col i K-12 
host-vector combinations carrying DNA coding for known polypeptide toxins 
could be among the experiments which would still remain under the Guidelines. 
[Appendix A — 163] 
