Laboratoire Europeen de Biologie Moleculaire 
European Molecular Biology Laboratory 
Europaisches Laboratorium fur Molekularbiologie 
From the Director-General 
Sir John Kendrew 
13 January 1978 
Dr D Frederickson 
National Institutes of Health 
Building 1, Room 124 
Bethesda MD 20014 
USA 
Dear Don 
I am writing, as you requested, to give my overall view of the proposed 
revisions of the Guidelines for Recombinant DNA research, in the light of the 
public hearings on 15 and 16 December last. I should first like to express 
my gratitude to you for your invitation to me to serve on this occasion as a 
member, and indeed the only non-American member, of your Advisory Committee. 
The opinions set out in this letter do not differ from those I expressed 
verbally during the closing session of the Committee on 16 December. 
The Proposed Revised Guidelines represent a significant downgrading of the 
containment requirements for different classes of experiment. I find the 
evidence that led your Committee to propose this downgrading very convincing, 
and I am persuaded that the revisions represent a step in the right direction. 
The extent of the downgrading is, of course, a matter for judgement - the phrase 
"to err on the side of caution" has been used, and it evidently reflects the fact 
that there is still public concern, and whether or not this concern is justified 
it is certainly real. On the other hand it is useless to issue strict guide- 
lines unless these have the respect of the scientific community. Evasion is 
easy, and the guidelines will not be followed unless they are thought to be 
reasonable. In the light of these conflicting tendencies (neither of which can 
be quantified by any amount of scientific argument) your Committee has proposed 
a step in the direction of relaxation. 
Here vie should note that, if what your Committee has proposed represents one 
step of relaxation, then in Europe both the EMBO Committee and the French 
authorities have made proposals that could be regarded as two steps in the 
same direction. 
My personal judgement is that, viewed strictly from a scientific viewpoint, 
the further steps of relaxation proposed in Europe are justified; that is, 
the revised NIH guidelines are still unnecessarily strict. However, I accept 
that the decision must be a function of the degree of public concern as well 
as of a purely objective assessment of risks. Against this background I find 
the NIH proposals perfectly reasonable. 
[Appendix A — 212] 
