3. Let's face it: There is no trace of any practical risk in cloning and 
studying human genes coding for, for instance, immunoglobulins; - and these 
extemely important and beneficial studies on our natural defenses against 
diseases are made very cumbersome and often impossible under the Guidelines. 
I cannot comprehend why most important, safe and very beneficial medical 
research on human genes and proteins that are involved in controlling our 
health should be greatly restricted. I could give many examples how the 
various studies of cloned genes could be of great benefit to basic science, 
to health sciences and to protecting our endangered environment. E.g., within 
the last few months an important and unexpected discovery was made, namely it 
was found that smack in the middle of our blood protein genes there are 
naturally inserted special DMA sequences which are not translated into 
proteins. 
To cite one more example, the recombinant DMA technique could have very 
beneficial impact on the production of safe and effective vaccines, especially 
since at present it is not possible to make vaccines against several important 
infectious diseases, e.g., Herpes II, which causes very painful, debilitating, 
dangerous and rather frequent disease, especially in women. The traditional 
approach, i.e., the use of directly killed Herpes II as vaccine would be very 
risky since there are strong indications that such inactivated virus may have 
a cancer-inducing potential. An appealing and safe way to proceed would be 
to try to produce pure antigens by the recombinant DNA technique. There is 
no indication of any practical risks in trying to produce a pure and safe 
vaccine by the recombinant DNA technique, but in most cases the Guidelines 
forbid it or make it rather impossible to do. 
Dr. Fredrickson, if the Guidelines are not modified as to permit and 
even encourage such rewarding directions as pure and safe vaccine development 
we may be justly accused of contributing to human misery and disease, 
with one example being the Herpes II i nfection, whi ch makes a woman not only 
miserable but also has been suggested as a predisposing cause of cervicd.1 
cancer. 
9. We as a nation will have to pay a very high, and totally unjust, price in 
diseases and misery which could be prevented, in lives not saved, in tax- 
payers' money (and I object as a U. S. taxpayer), in lost talents, in lost 
freedom of inquiry, in loss of respect for the N.I.H. regulations because 
some parts have no sound scientific basis, in misleading the Congress and 
public, and in misdirecting the environmental movements, among others. This 
all happens because the restrictive nature of the Guidelines misleads and 
frightens the layman who believes that the imposed restrictions indicate 
real dangers and not just .. imaginary risks. 
10. And why shall we do it? In the name of the imaginary risks which we know 
now are of no practical concern, being something much less than one minor 
illness (maybe upset stomach) per 10,000 or 100,000 years of research in 
10,000 or 100,000 laboratories? 
Dr. Fredrickson, members of the Advisory Committee, I urge you 
emphatically to make a courageous and very sound decision, i.e., to exclude 
most of the EK1 and EK2 novel recombinant DNA experiments from the Guidelines, 
and perhaps just require these experiments to be simply registered with the 
N.I.H. Office of Recombinant DMA. I am honestly concerned that history may 
judge us very harshly, since some time from now it will be possible to 
calculate how many lives were unnecessarily lost, how much human misery was 
prolonged because of delays in beneficial research as imposed by the restrictive 
Guidelines and ensuing regulations. 
I shall be glad to answer any questions and I would appreciate it if 
you would let me question other witnesses appearing here, if their statements 
should be in conflict with the known facts. 
[Appendix A — 164] 
