The hazard of using bacteria v;hose niche is the 
mammalian gut and the possible repercussions of this are in no 
way discussed in an adequate, informed manner. 
2. The pathways by which free DNA combines v;ith 
a living cell are not discussed and the only treatment of the 
probabilities of such recombination is a brief statement that 
such a reaction is "considered remote" (p. 24) . The mechanism 
of transformation by which DNA enters an organism is well known, 
yet the DEIS does not mention literature on the subject or 
back up its statement. Also, survival times and viability of 
these recombinants are not discussed. The DEIS claims that 
the viability in air, water or other media, is not significant. 
The definition of significant is never given. Even a few days 
or hours of survival could be sufficient to transfer harmful 
genes. The published literature on the viability of E. coli 
should have been included. 
3. In the discussion of laboratory safety the DEIS 
states that "potentially harmful effects from research with 
high risk recombinant DNA molecules should be extremely unlikely 
given strict adherence to the NIH Guidelines" (p. 63) . No 
literature is presented to support this statement. For example, 
the well known Wedum report documenting 3 deaths and 423 
infections in Fort Deitrich was not mentioned. No information 
of past biohazard program success, human error risks in 
Iciboratory practices, or history of containment failure 
-13- 
Appendix K — 93 
