COVINGTON 5. BURLING 
Donald S. Fredrickson, M.D. 
March 3, 1978 
Page Eighteen 
changes in the Guidelines should then be promulgated. 
There should be no barrier whatever to appropriate reclas- 
sification of experiments, permitting less stringent physical 
or biological containment, as long as there is adequate 
scientific justification and full public disclosure and 
participation . 
3. The development of new host- vector systems 
appears to be generally regarded as a very high priority. 
NIH should accordingly place significant emphasis in this 
area. 
4. Perhaps because of the inherent difficulties 
of a risk assessment or a benefit/risk analysis, very little 
has been done in this area to date. NIH should, as one of 
its highest priorities, fund substantial work with respect 
to these matters in order more adequately to respond to 
the public concern about this type of experimentation. 
5. It appeared from the discussion during the 
December 1977 meeting that NIH has not actively sought out 
researchers working on research on recombinant DNA mole- 
cules in private industry or in other institutions funded 
from non- government sources. I believe that this is a mis- 
take, and that NIH should aggressively seek out these re- 
searchers and invite them to participate in the work of the 
Recombinant Advisory Committee and other related activities. 
This would cement the leadership of NIH in this entire area. 
VIII 
In conclusion, I wish to reiterate my general sup- 
port both for the concept of the Guidelines and for the 
specific intention of the proposed modifications to reduce 
or eliminate current requirements wherever such reduction or 
elimination is scientifically justified. NIH was right when 
it concluded to issue the Guidelines, in order to reassure 
the public about the safety of this experimentation, and it 
is equally right in modifying the Guidelines to reflect new 
scientific information. Greater care must be taken in the 
future, however, to assure the procedural integrity of the 
Guidelines and to reflect due process of law in proposing and 
adopting amendments . I have enormous admiration for the 
great amount of work that NIH and outside scientists have put 
into this effort, and believe that it deserves the praise and 
support of the entire public. sn 
Since/aiy yours, 
(jjlu 
Peter Barton Hutt 
[Appendix A — 256] 
PBH/mh 
Enclosure 
