The Public Health Research Institute 
of the City of New York. Inc. 
4SS First Avenue, new York. N. Y. lOOie 
Til. (212) 578 0600 
Office of the Director 
January 16. 1987 
Dr. William S. Gartland 
Office of Recombinant DNA Activities 
Building 31, Room 3310 
National Institutes of Health 
Be the sda , MD. 20892 
Dear Bill, 
I am writing to support Option 1 of the proposal to amend the 
Guidelines as stated in FR 51, p. 45651, December 19, 1986. 
I have previously submitted materials in support of this concept 
and I enclose herewith two documents. First is a proposal to amend the 
guidelines essentially as in Option 1, that I prepared last year to be 
submitted on behalf of the five members of the original "Plasmid forking 
Group" (PVG) who drafted the document that became the actual basis of 
the guidelines. This proposal was approved by all except Stan Cohen who 
had some reservations that were never addressed; consequently, the 
proposal was never submitted. The second document is the text of a 
piece I had written at the time in hope of publication in the New Tork 
Times. It never got published but I submit it herewith as a more 
elaborate statement of the same position. It contains diagrams which 
may be informative to the lay members of RAC. 
I believe these documents state fairly clearly my support for 
Option 1. I know Jon Ring and Liebe Cavalieri have argued that deletions 
constructed in vitro by splicing techniques are not equivalent to 
natural deletion. This argument is not supportable on genetic grounds 
— the relevant property of a deletion is that it does not revert; while 
it is true that the precise endpoints of an in vitro deletion are 
unlikely to be the same as any natural deletion, I do not see how this 
fact could have any possible biological consequences per se . 
or could possibly impact on the biohazard question, or could possibly 
be used to defend the position that in vitro deletions are in 
principle different from in vivo ones — after all, it is only 
unlikely, not impossible that the two could be identical. 
Sincerely yours. 
enc. 
RN/de 
Recombinant DNA Research, Volume 1 1 
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