January 4, 1978 
Dr. Donald Fredrickson, Director 
National Institutes of Health 
Department of Health, Education 
and Welfare 
Bethesda, Maryland 20014 
Dear Dr. Fredrickson: 
I am writing to express my opposition to the proposed revisions 
C9/27/77) of the NIH Guidelines for Research Involving Recombinant 
DNA Molecules. As a developmental biologist specializing in gene 
control in vertebrate systems, I am concerned that very little atten- 
tion has been paid, both in the original Guidelines and in the 
proposed revisions, to current ideas (and ignorance) of the origins 
of pathogenicity. It seems to me that none of the evidence presented 
in the Background document (November 1977) compiled by your office in 
support of relaxing the Guidelines speaks to points raised by Dr. 
Robert Sinsheimer and others in criticism of the 1976 document. 
To illustrate my concerns, I would like to juxtapose some passages 
in the Background document with some passages from a recent article in 
"The New Yorker" magazine (January 2, 1978) on Dr. Lewis Thomas, 
president of the Memorial Sloan-Kettering Cancer Center, a specialist 
on the interaction of bacteria with higher organisms. Though Dr. 
Thomas himself minimizes the hazards of recombinant DNA research, 
several of the points he raises suggest a more cautious approach is 
in order. 
. . . .E_. coli K-12 is so severely enfeebled in many of the 
properties that are necessary for survival in nature and 
for pathogenicity that it is incapable of being inadvertently 
converted into an epidemic pathogen by the insertion of DNA 
by recombinant techniques. (Background. . .p. 32.) 
. . . .E. coli K-12 will colonize the artificial intestinal 
environment of germ-free mice. (Background. . .p. 30.) 
[Appendix A — 183 1 
DEPARTMENT OF BIOLOGICAL SCIENCES 
STATE UNIVERSITY OF NEW YORK AT ALBANY • 1400 WASHINGTON AVENUE • ALBANY, NEW YORK 12222 
