Original Repository: Stanford University Libraries. Department of Special Collections and University Archives. Paul Berg Papers
Reproduced with permission of Paul Berg.
Medical Subject Headings (MeSH):
Recombinant DNA Technologies and Researchers' Responsibilities, 1973-1980
January 22, 1982
Dear Dr. Gartland,
I am writing in support of the RAC proposal to revise the NIH Guidelines for Recombinant DNA Research as set forth in the
Federal Register of December 4, 1981.
I believe that the Guidelines for Recombinant DNA research are now dispensable. Based on the substantial amount of experience
and experimentation with the recombinant DNA methodology during the last six years, there is widespread agreement that the
risks that were once thought to be so plausible are actually remote or possibly nonexistent. If that judgment is indeed correct,
and I know of no evidence to indicate otherwise, then it seems wasteful of effort and money, even counter-productive, to maintain
the elaborate procedures and organizations that were setup to guard against the hypothetical threats. It has been my long-held
view that the most beneficial feature of the Guidelines was their educational role; they highlighted the kind of concerns
that were voiced and provided recommendations for workers in the field as to how safety considerations should be incorporated
into their experimental designs and procedures. For that purpose referring to the revised Guidelines as a Guide (or Code)
for Good Practice seems appropriate.
There is one minor point in the wording of the RAC proposal with which I differ. Emphasizing that the new recommendations
are 'voluntary' places an unintended and unnecessary psychological focus on the change. I suspect that if the voluntary
nature of the recommendations is emphasized, many will take that as an invitation to ignore them completely; after all who
cares. But if the revised version makes strong recommendations and accompanying justifications for how such experiments should
be carried out, there is a stronger likelihood that people would accept the recommendations as being reasonable. I prefer
the approach the CDC uses, namely, to advise scientists of the concerns about certain organisms and make recommendations for
how to work with various types of microbial pathogens and viruses. Voluntarism, while implicit, is deemphasized in favor of
I am strongly in favor of maintaining RAC but not necessarily ORDA except in so far as it serves a small staff function for
RAC. RAC could well serve as an 'antenna' and 'intelligence' group in that their role would be to monitor
progress and developments of recombinant DNA technology being alert to any developments that could bear on the issue of safety.
RAC could be the trigger to initiate an appropriate response to any perceived or actual risk. I think that if RAC were constituted
to provide such a 'watch guard' function and was responsible for responding to unanticipated developments, there might
be less concern on the part of the public by what will be perceived as a drastic change in the regulations of this research.