Roy Curtiss was an attendee at the Asilomar Conference and member of the Recombinant DNA Molecule Program Advisory Committee,
which evaluated the safety risks and containment requirements of recombinant DNA experiments. After first agreeing to the
voluntary moratorium on such experiments, Curtiss came to regard genetic engineering experiments involving the much-studied
K-12 strain of the bacterium Escherichia coli as harmless, and called for revising the NIH guidelines to ease E. coli K-12
containment requirements. In this letter he addressed problems of definition of what constituted recombinant DNA molecules
in Congressional bills that sought to achieve the opposite: to impose stricter regulation of recombinant DNA research.
Number of Image Pages:
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1977-05-20 (May 20, 1977)
Curtiss, Roy III
University of Alabama in Birmingham
Original Repository: Library of Congress. Maxine Singer Papers
Reproduced with permission of Roy Curtiss III.
Medical Subject Headings (MeSH):
Guidelines as Topic
Risk, Regulation, and Scientific Citizenship: The Controversy over Recombinant DNA Research
Letter from Maxine Singer to Roy Curtiss III (June 3, 1977)
At the May 14-15, 1977 meeting of the NIH Recombinant DNA Molecule Program Advisory Committee various revisions were proposed
in the 1976 version of the NIH Guidelines for Recombinant DNA Molecule Research. The Advisory Committee will meet again toward
the end of June to complete its revision of the Guidelines and to review changes already made. One of the major issues under
consideration was a redefinition of the types of recombinant DNA molecule activities to be regulated by these guidelines.
As most of you are aware, the legislative bills introduced by Senator Edward Kennedy and by Congressman Paul Rogers both exempt
certain recombinant DNA molecule experiments from the regulation. The NIH Advisory Committee also considered this issue and
drafted appropriate definitions and statement of intent as to which experiments are or are not included. A copy of the proposed
first paragraph of the Guidelines is enclosed for your information.
The second sentence includes a definition of recombinant DNA molecules much as it was given in the 1976 version of the Guidelines.
The third sentence defines "novel recombinant DNAs" as arising from the joining of segments of any DNA from different
species that are not known to exchange chromosomal DNA by natural physiological processes and indicates that the Guidelines
will pertain only to these novel recombinant DNAs. The fourth sentence provides a clarification so that it is clear that formation
of recombinant DNAs between viral, extrachromosomal or chromosomal DNAs are excluded from the Guidelines when all components
are known to replicate in the prokaryotic host organism used to propagate the recombinant DNA. The fifth sentence, however,
states an exception and specifies that certain types of recombinant DNAs that might not be novel that are formed between a
eukaryotic viral DNA and eukaryotic DNA are included under the Guidelines. The last sentence indicates that it is the responsibility
of the Director of NIH to establish a list of the types of recombinant DNA molecules that are excluded from the Guidelines.
I would very much appreciate any comments you have on these definitions and provisions so that the NIH Advisory Committee
at their June meeting can make any necessary changes. It should be evident that the purpose of these statements is to exclude
those experiments which most would agree have no risk associated with them. This exclusion would undoubtedly eliminate 75%
of the paperwork associated with grant submissions, filling out of Memoranda of Understanding and Agreement and activities
of institutional biohazards committees.
Roy Curtiss III
cc: William J. Gartland
Members, NIH Recombinant DNA Molecule Program Advisory Committee