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2. The Recommendation That All Permissible Recombinant DNA 
Experiments Be Conducted TrTNational Facilities 
A number of commentators addressed their remarks to alternatives 
in which all recombinant DNA research would be conducted in a single 
or a few national facilities [12, 2 7, 30], or all such work would be 
limited to P3 or P4 facilities until more is known about the new tech- 
niques [20, 24, 2 6, 2 9]. Because these suggestions represent variations 
of the same theme --namely, the restriction of all DNA research 
activities to certain facilities --they raise basically the same issues, 
and the EIS has been revised to discuss these alternatives as a whole. 
Thus, where the Draft EIS had contained two separate sections 
("establish a few national P3 facilities" and "conduct all recombinant 
DNA experiments in P4 facilities"), the revised EIS takes up this subject 
in a single section, VI-C-2. The provision of national facilities for 
conducting some of the research requiring P4-level containment is 
feasible and is being considered by the NIH. 
3. Experiments Prohibited at This Time 
A number of commentators would prohibit certain classes of experi- 
ments that are now permissible under the Guidelines [12, 34]. Several 
expressed concern over the advisability of permitting recombinant DNA 
experiments using E. coli host-vector systems [3, 20, 25, 30, 36]. As a 
result. Section VI-C-3-b of the EIS has been expanded to describe the 
situation in more detail [7]. Several useful technical references are 
given. These questions are also discussed in some detail in the Guide- 
lines themselves (Section III-A). 
A new appendix has been added to the EIS (Appendix M) which describes 
a recent Workshop on Studies on Assessment of Potential Risks Associated 
with Recombinant DNA Experimentation, held at Falmouth, Massachusetts, 
on June 20-21, 1977. 
Essentially, E. coli strain K-12 should not be characterized as 
a pathogen; and a - major advantage of using E_. coli instead of other 
bacteria is the immense knowledge of its genetic makeup and biochemical 
pathways. Because of this knowledge, well-characterized and precisely 
located mutations can be introduced into the K-12 strain by standard 
genetic techniques, to create variants that have specific disabilities 
precluding their survival in nature. 
There is no other bacterium whose characterization even remotely 
approaches that of E. coli K-12. Two principal advantages for its 
use in recombinant~DNA research are as follows: 
• Laboratory strains of E. coli have never been observed to cause 
disease in laboratory workers. 
