THE J. HILLIS MILLER HEALTH CENTER 
UNIVERSITY OF FLORIDA 
Department of Biochemistry Phone: 904-392-3361 
and Molecular Biology Gainesville, 326 1 0 
May 2, 1978 
Dr. Donald S. Fredrickson 
Director 
National Institutes of Health 
Bethesda, Maryland 20014 
Dear Dr. Fredrickson: 
I have just sat through the April 27-28 meeting of the Recombinant 
Advisory Committee at the NIH. As a result of this meeting, and taking into 
account my experience on the University of Florida Institutional Biohazard 
Committee, I would like to offer several comments for your consideration 
when the Guidelines for Recombinant Research are revised by your office. 
The main purpose of the Guidelines, to my mind, has been to make 
scientists think about their experimentation, not to insure safety per se. I 
regard most experiments as safe, as long as precautions are taken to insure 
proper disposal of all recombinant organisms. It is for this reason that I 
believe no experiments should be exempted from the Guidelines. If 1 aboratory 
workers realize they are doing recombinant research, and realize there is a 
possible hazard, then I believe the spirit as well as the rules will be 
observed. By exempting experiments, usual laboratory procedure will be followed. 
Why cannot al 1 recombinant experiments be carried out as P] experiments under 
the Guidelines, but review for many safe experiments be minimal or non-existent. 
I am opposed to blanket exemption from the Guidelines, and indeed I feel that 
just as radioisotope use is recorded, use of this technology, with its potential 
for permanent change of the environment, should be monitored. 
I. Scientific Comments 
A. A large class of experiments using recombinant DNA technology to trans- 
fer genetic information between various bacterial species have been exempted 
from the proposed Guidelines. On the basis of frequent transfer of chromosomal 
genes in nature , I agree that organisms listed in Tables 1 and 2 (see attached 
copy) present no unusual hazards. However, the extended Table 3, comprising 
essentially all of the gram negative bacteria, does not meet this criteria. All 
organisms in this table have been shown to transfer plasmids to £. col i ; no 
information was given on the frequency of this event in nature, and no informa- 
tion was given on transfer between organisms other than £. col i . Considering 
the ecology of many of these bacteria, natural transfers of genetic information 
are probably nonexistent between many organisms in Table 3. Based on this 
concept, "probable natural genetic transfer", I would argue that organisms 
present in Table 3, not represented in Tables 1 and 2, should remain under the 
Guidelines, at PI or P2 levels of containment. 
[Appendix A — 293] 
EQUAL EMPLOYMENT OPPORTUNITY ,'A FFIRMA TIV E ACTION EMPLOYER 
