UNIVERSITY OF WASHINGTON 
SEATTLE, WASHINGTON 98195 
School of Medicine 
Department of Microbiology, SC— 42 
and Immunology 
April 16, 1976 
Dr. DeWitt Stetten 
Deputy Director for Science 
Department of Health, Education, 
and Welfare 
Public Health Service 
National Institutes of Health 
Bethesda, Maryland 20014 
Dear Dr. Stetten: 
I wanted to put in writing one point of concern about the proposed 
guidelines for research involving recombinant DNA molecules that came 
out of the discussions at the meeting to which I was invited as a 
consultant. This concern relates exclusively to administrative 
aspects on pages 41 to 44 of the draft of the tentative guidelines, 
I consider the rest of the document to be superb and to give a very 
completely thought through series of recomnendations which will, 
I believe, suffice to protect the public and the environment from 
even extraordinarily improbable events as long as they are followed - 
and thereby hangs my concern. 
Experience of laboratory infections with pathogenic microorganisms 
shows that recognized precautions often have not been followed or 
have become' eroded with time because difficulties have not previously 
arisen. I predict that if one visits clinical chemistry or serology 
laboratories in many large centers one would find a considerable 
proportion which are not using the most elementary recognized precautio 
for avoiding the known risk of hepatitis. On the other hand, where 
state regulations exist concerning the handling of Mycobacterium 
tuberculosis , and the laboratories are subject to inspection, the level 
of care used tends to approximate that which is recommended and which 
is needed for personnel protection. I use these examples to point up 
that recommendations without local responsibility for enforcement other 
than the judgment of the individual principle investigator are often 
relatively ineffective. This is likely to be compounded when precautio 
are invoked for theoretical hazards which have never been realized in 
practice. 
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G305 Health Sciences Building / Telephone: (206) 543-5824 
