COMMENTS CONCERNING PROPOSED REVISIONS TO THE NIH 
GUIDELINES FOR RECOMBINANT DNA RESEARCH 
While this conference was called to examine the proposed revisions to the NIH guide- 
lines, these cannot be considered without some reference to the initial existent 
guidelines . 
From my point of view, the guidelines are informed by a perspective which is: 
1) Extraordinarily anthropocentric. The whole framework of containment 
provisions exhibits a dominant bias toward the specific protection of human 
beings. The containment requirements parallel presumed phylogenetic 
relationships to man. Provisions for containment of viral nucleic acids 
(or components) reflect the ability of such viruses to grow in primate or 
human cells. 
The necessity for the protection of other species is given much less weight, 
if any. Such a view is, at best, a short-sighted anthropocentrism. The 
importance of plants was frequently mentioned at this meeting. Similarly 
many, many other life forms — microbes, nematodes, insects, etc., play vital 
ecological roles. We should be concerned with their safety as well. 
Even with respect to man, the guidelines reflect the experience and capabilities 
of disease containment in more advanced countries with excellent sanitation 
and medical facilities. They seem much less reflective of the disease potentials 
in the less advanced societies which include most of humanity. With modem 
transportation one can hardly be confident of restricting the spread of any 
microbial strains . 
2) Extraordinarily confident of the completeness of our knowledge of micro- 
organisms and of our ability to predict the consequences of changes of scale 
of lO 10 or greater. The complexitv of bioloaical oraanisms seldom provides 
the unexceptionable generalizations found in physics or chemistry, 
3) Dangerously narrow in their preoccupation with recombinant DNA to the 
exclusion of other forms of genetic research capable of producing recombinant 
cells and organisms of unknown potentials, i.e., cell fusion, chromosomal 
transfer. 
Such a perspective continues to be manifest in the proposed revisions. It may indeed 
represent the political "center" but it does not to my mind reflect the objectivity 
with which we are familiar in everyday science. 
To turn to the "Revisions." There appear to be two general classes: 1) Those which 
represent "tidying up" the language or details of the existent Guidelines, e.g. 
improving the definition of recombinant DNA, introducing the HV nomenclature, etc. 
With most of these I have no quarrel. I do suggest that the proposed revised and 
expanded classification of research with viral or sub-viral genomes has not been 
thoroughly thought through and needs more analysis. 2) Those which represent a 
downgrading of the required containment provisions, based principally upon the "new" 
information as to the properties of E. Coli K12. 
With these I cannot at this time agree. In the first place the "new" information 
is not, in large part, available to me nor to the scientific community where it can 
[Appendix A — 180] 
