-3- 
Page 36. Following the discussion of the physical safeguards 
(grouped into four levels providing increasing capability for 
containment) , we believe it would be useful to emphasize 
that the guidelines require (for all four levels) that 
liquid and solid wastes contaminated with recombinant DNA 
material shall be decontaminated before disposal. 
The discussion of an additional safeguard of biological 
containment appears reasonable. However, assurance is needed 
that genetic manipulation of a crippled strain of E. Coli 
would not accidentally create a dangerous organism which 
could infest human intestines. 
Page 37 and 38. Review of the ten factors governing the 
danger of experiments makes it clear that danger depends 
on many uncertain or unknown factors. This seems particularly 
true of numbers 4, 9 and 10; i.e., "the ability of the vector 
to survive in natural environments or habitats," "the potential 
of the recipient to obtain the source DNA by natural means," 
and "the evolutionaary relatedness of the source DNA to 
humans." In addition, while it is certainly appropriate to 
focus on human health, we v/ould suggest that non-human 
species also be considered when assessing dangerous 
possibilities . 
Page 39 - In the discussion of the qualifications and expertise 
of advisory committee memberships, the potential value of 
specialists in population dynamics and in ecology should 
not be overlooked. 
Pages 50 and 51 - The arguments presented seem to favor 
a limited number of containment facilities for conduct of 
P3 and P4 experiments. We believe that the number of 
facilities should be limited in the beginning, at least, as 
they were in the early days of research involving radioactiv;Lty . 
Page 56 
* There is merit to the idea that the Occupational 
Safety and Health Administration (OSHA) be petitioned to 
enforce and monitor recombinant DNA research through its 
standard procedures. It would seem likely that if NIH does 
not, then some other group will do so especially when the 
new technology becomes industrialized. 
• EPA supports the idea of legislation that would 
increcTse the scope of control and reduce the possibility of 
deleterious environmental effects likely to result from 
recombinant DNA research. 
Page 67 - c. Early Recognition of Potential Hazards. 
The discussion presented in this section points up the 
responsibility of a principal investigator under the 
Appendix K — 163 
