CALIFORNIA INSTITUTE OF 
TECHNOLOGY 
PASADENA, CALIFORNIA 91109 
DIVISION OF BIOLOGY 
February 5» 1976 
Dr. Donald S. Fredrickson 
Office of the Director 
National Institutes of Health 
Bethesda, Maryland 20014 
Dear Don: 
I have read with some care the recommendations of the Recombinant DNA Committee 
and the associated material your office has sent to me. Since you have asked 
me to serve as an ad hoc member on your Advisory Committee to review these 
recommendations, you may be interested in my reactions. Conceivably my 
opinions may be changed by the discussion at next week's meeting, but I feel 
obliged to say at this time that, in my judgement, the precautions proposed 
for recombinant DNA research in the committee recommendations are simply 
inadequate. 
Although it may seem contrary, in saying this I do not wish to be critical of 
the committee. It is composed of outstanding people, representing a consider- 
able spectrum of views. It is inherent then in the operation of such a committee 
(especially in an area so devoid of hard data) that it will seek some compromise 
position that tfill command enough support that it can perform its function. 
However, unfortunately, some issues in life do not brook compromise; sometimes 
the middle ground can be worse than either extreme. 
Understandably the committee concerned itself with specific and reasonably 
definable potential hazards - the possible consequences of the incorporation of 
nucleic acids from pathogenic or tumorigenic organisms (wittingly or unwittingly) 
into microorganisms - and devised a graded series of precautions accordingly. 
It is clear that the committee did not consider that there could be any hazard 
from the simple incorporation of eukaryotic DNA per se into microorganisms. 
Thus the precautions to be taken with a clone bearing a well defined eukaryotic 
DNA are minimal. 
I believe that this position is unjustified and indeed untenable. 
First of all, I cannot believe that under these proposed guidelines the organisms 
can be contained. If work is going on in a hundred laboratories about the 
United States, performed by technicians, graduate students, etc., the organisms 
will inevitably escape - and will enter into the various ecological niches known 
to be inhabited by E. coli. 
[ 436 ] 
