2 
past experience is, at the least, unscientific. An 
illustration of this point can be found in the paper Roy 
Curtiss submitted to the Advisory Committee to the 
Director of the NIH. In this paper, he states that "Most 
foreign DNA causes a microorganism that possesses it to 
be at a distinct selective disadvantage in competing with 
other bacteria. I thus consider that in on]^ of the 
cases will foreign DNA be beneficial to and/or no burden 
on the bacterial host." The conversion from most to a 
concrete number {\%) is a very intriguing mathematical 
process, one I don’t profess to understand, especially in 
light of the fact that many of these experiments have 
never been done before. With all the variables involved, 
the probable effect of foreign DNA cannot be represented 
by such a simple value. Because this is a new technique 
creating novel organisms, we cannot expect it to follow 
the behavior we observed before-some, perhaps even a 
majority of the experiments would produce more viable 
bacteria rather than the opposite case. 
The second stipulation in Paul Berg's letter (to develop 
adequate protection methods) has been effectively ignored 
by the present NIH policy. To allow - actually promote - 
the proliferation of DNA research centers have effectively 
negated the proposed physical containment levels. As 
studies at Fort Detrich have shown, poor lab techniques 
can ruin the best physical containment procedures. To en- 
courage this research is to create the push for new dis- 
coveries, causing more and more lab personnel to become 
involved in it and increasing the likelihood of outside 
exposure . 
The biological containment is at least as ineffective, for 
the use of E. coli as the bacterial host is the first dis- 
advantage. Secondly, in all of the discussion of the sur- 
vival rate of the EK2 vectors in the guidelines, no mention 
is made of the time interval over which the bacteria 
population is to decrease to 1 x 10”° of it's initial 
value . 
An extension of the second point is that even if the bac- 
teria die outside the laboratory, they can still exchange 
genetic information with living cells. 
I conclude, then, that the present measures to protect the 
public can only be described as inadequate. To confine the 
research to one facility (such as Fort Detrich), in order 
to give effectiveness to the physical containment levels, 
until the dangers are more accurately assessed seems to me 
to be the only responsible position at this time. In 
addition, extensive research for a better host should be 
undertaken. 
Appendix K — 155 
