THE UNIVERSITY OF MICHIGAN 
ANN ARBOR, MICHIGAN 48104 
Department of Humanities 
College of Engineering 
(313) 764-1420 
21 April 1976 
Dr. Donald Fredrickson 
Director 
National Institutes of Health 
Bethesda, HD 20014 
Dear Dr. Fredrickson: 
We write to express our concern over several aspects of 
recombinant DNA research which we feel are of critical impor- 
tance and to recommend that they be addressed by the Recombinant 
DNA Molecule Program Advisory Committee before the guidelines 
are disseminated to the NIH grantees and contractors. 
In the first place, we feel that the data presented by 
Dr. Curtiss to the committee in April in his paper, "Construc- 
tion, Properties and Testing of X 1776" raises serious doubts 
about the effectiveness of biological containment. Dr. Curtiss 
himself points out in the introduction (p.3) that this strain 
does not satisfy the criteria for a disarmed strain set down in 
the guidelines drafted at La Jolla. Specifically, the degrada- 
tion of cloned DNA fragments is not guaranteed, and in fact, has 
not been tested by Dr. Curtiss since his experiments have been 
carried out on a host- vector system not containing cloned DNA. 
Furthermore, it appears from much of the data presented that the 
strain X 1776 can survive both in the dry state (pp. 131-132) and 
in a variety of environments including tap water (pp. 127-12 8) 
for considerable periods. In the light of this evidence, we 
think it is essential that the committee's discussion of the 
properties of X 1776 and its decision to certify or not to cer- 
tify this strain as a disarmed strain be carried out in public. 
If it is not contrary to the letter of the regulations governing 
the conduct of the committee, it is certainly contrary to their 
spirit that this important issue be decided by mail, as was pro- 
posed at the April 1-2 meeting. 
Second, the committee should write an Environmental Impact 
Statement as required by the National Environmental Policies Act 
of 1969. Dr. Richard Andrews of the University of Michigan 
School of Natural Resources has written to you about the appli- 
cability of this law. 
Third, the committee should write a statement on the feasi 
bility and costs of monitoring, both of laboratory personnel and 
of the environment. If effective monitoring turns out to be 
difficult or impossible, or beyond the financial means of most 
universities, then we think that you and the committee should 
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