U IV I V E Ft 
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ORPO RAT X O 1ST 
GARY W. SANDERSON, RH.O. 
VICK MCIiOKNT>«MCA»CN 
January 15, 1987 
The Director 
Office of Recombinant DNA Activities 
Building 31, Room 3B10 
National Institutes of Health 
Bethseda, MO 20892 
Oear Sir: 
I am writing to comment on the Notice ‘Recombinant DNA Research: 
Proposal Actions Under Guidelines* published In the Federal Register on 
December 19, 1986 (51 FR 45650-45652). 
I heartily support all of the proposals listed In this Notice, but I 
particularly want to support the changes In the "NIH Guidelines for Work with 
Recombinant ONA Organisms* that are proposed by Dr. Frank E. Young, 
Commissioner of Food and Drugs (51 FR 45651, Column 3, to 51 FR 45652, 
Column 2). Dr. Young's comments state the Justification, and the need, for 
relaxing the NIH Guidelines to allow safe recombinant organisms to be cultured 
In the same way that one cultures organisms of the same type that are 
genetically unmodified by recombinant DNA techniques. Dr. Young's comments 
are concise and they are accurate; and they deserve to be supported. 
My company (Universal Foods Corporation) Is one of the world's largest 
manufacturers of baker's yeast ( Saccharomyces cerevl slae ) and other yeast 
products. Our brand name for yeast products Is *Red Star™,* and we 
manufacture and market these products In nine countries around the world In 
addition to the United States. This product has been consumed as a food, and 
as a constituent of food products, by people the world over for centuries. 
Without exception, baker's yeast In all of Its forms Is recognized as a 
wholesome food material that Imparts aesthetically pleasing qualities to many 
food products (especially flavor and leavening to bakery products). And, 
various forms of the yeast Saccharomyces cerevlslae (such as baker's yeast and 
brewer's yeast) are also recognized to be Important sources of vitamins and 
minerals, and they are consumed for these beneficial constituents by many 
people. 
There Is certainly unanimous agreement that the yeast Saccharomyces 
cerevlclae Is a safe organism. And the Insertion of genetic material for safe 
proteins, and for enzymes that promote Innocuous reactions, Into the yeast 
Saccharomyces cerevlslae does not change the safe nature of the original 
organism. For Instance, In our laboratory, we have Inserted genes for 
■lactose permease* and for *beta-galactos1dase" from the yeast K1 yveromyces 
lactls Into a baker's yeast strain of Saccharomyces cerevlslae in order to 
TECHNICAL CENTER 
€ ' A 3 NORTH 6 0 STREET MILWAUKEE. WISCONSIN 52216 
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