University Health Service 
Division of 
Environmental and Occupational 
Health and Safety 
John W. Wilce Student 
Health Center 
1875 Millikin Road 
Columbus, Ohio 43210 
Phone 614 422-0153 
Dr. William J. Gartland, Jr. 
Director, Office of Recombinant DNA Activities 
NAIAD 
National Institute of Health 
Bethesda, MD 20205 
Dear Sir: 
I am the Biological Safety Officer for the Ohio State University and I strongly 
disagree with the RAC's recommendation to allow Dr. John Murphy's experiments 
with diphtheria toxin even under P-4 conditions. I encourage the RAC to 
reconsider this decision. 
The brief description in the Federal Register of the proposed experiments and 
the anticipated results may not accurately express the value of this protocol. 
Nevertheless, it appears to me that some exploratory work is needed before 
embarking on a recombinant DNA project. For instance, if germ free animals 
were used, it would not be necessary to reduce the normal flora with "broad 
spectrum antibiotics". Also, it would not be necessary to prove, in a 
follow-up experiment, that the "broad spectrum antibiotics" did not alter the 
permeability of the lower GI tract. If manipulation of the normal flora is 
necessary, a gavage of a pure culture of corynebacterium or a cocktail of 
"defined flora microorganisms" would appear to be superior to the antibiotic 
treatment. This technique would allow for reliable replication which may not 
be possible under the antibiotic procedure. 
One of the reasons for the general acceptance of recombinant DNA technology is 
that it has provided investigators a means to accomplish results not possible 
by any other procedure. Experiments on the absorption of polypeptides and 
cytotoxins from the lower GI tract can be accomplished without employing 
recombinant DNA technology. To jeopardize the public acceptance of recombinant 
DNA research to obtain results which can be obtained by other means, does not 
appear to be justified. 
Sincerely , 
The Ohio State University 
January 4, 1983 
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