UNIVERSITY OF CALIFORNIA, IRVINE 
BERKELEY • DAVIS • IRVINE • LOS ANGELES • RIVERSIDE • SAN DIEGO • SAN FRANCISCO 
SANTA BARBARA • SANTA CRUZ 
DEPARTMENT OF CHEMISTRY IRVINE, CALIFORNIA 92717 
January 13, 1978 
Dr. Donald S. Fredrickson, Director 
National Institutes of Health 
9000 Rockville Pike 
Bethesda, MD 20014 
Dear Dr. Fredrickson: 
I am writing to present my comments on the proposed changes in the NIH recom- 
binant DNA research guidelines, as discussed in the December 15-16 meeting of 
the Advisory Committee to the Director, NIH. 
Until recently I knew very little about the recombinant DNA controversy. Most 
of my original fears disappeared rapidly as I became better informed, and I now 
tend to agree with the consensus of the experts in the field, which appears to be 
that the original fears--say, of spreading an uncontrollable epidemic- -were 
exaggerated. Several statements presented during the December meeting--such 
as those of Dr. James Watson, Dr. W. Szybalski and Dr. Bernard Davis — were 
rather convincing to this point. 
On the other hand, there are numerous examples of situations where unforseen 
problems have arisen when scientific discoveries were applied on a commercial 
scale, perhaps as a consequence of the transition from science to technology 
(i.e. , radiation damage, release of chemicals to the environment, etc.). In 
retrospect, the ’’experts” often took an overly narrow point of view as to the 
potential hazards associated with their activities. In the case of recombinant 
DNA technologies, one can easily imagine that problems might arise even before 
these technologies are exploited on a commercial scale because of the potential 
for self-replication; of course, the risk will increase with the rapid prolifera- 
tion of these technologies, but the worry is that it is sufficient, in principle, for 
a single event- -say, the accidental production through a contaminated sample of 
a small number of chimeric organisms which somehow manage to escape and 
reproduce in the environment — to have widespread and long lasting harmful 
effects on the ecosystem for which there might be no effective countermeasure. 
Among others, Dr. Robert Sinsheimer and Dr. Jonathan King articulated some 
of these possibilities, so that this type of worry is not unique to outsiders to the 
recombinant DNA field. 
It seems to me that from a scientific point of view this general matter of risks 
to the environment- -as opposed to some rather specific questions, such as 
[Appendix A — 214] 
