Dr. Donald S. Frederickson 
2 
The impact statement and the guidelines stress what is new. That is 
the technology for forming recombinant DNA molecules Iji vitro , and the 
unknown potential of the newly formed DNAs. 
We agree that the assessment of potential risks and benefits of the 
new technology for forming recombinant DNA molecules jji vitro must be 
thorough and responsible and allow for change in the light of new 
knowledge . 
Since there is likelihood that some might take Section VII, 
"Environmental Impact of the Guidelines," (beginning on page 59), out 
of context, we would suggest that the following explicit definition of 
recombinant DNA molecule research as contained in the guidelines be 
repeated in the first paragraph of Section VII: "...we define 
recombinant DNAs as molecules that consist of different segments of 
DNA which have been joined together in cell-free systems, and which 
have the capacity to infect and replicate in some host cell, either 
autonomously or as an integrated part of the host's genome." 
Another concern pertains to special features of the P4 facility for 
high risk level research as described on page 44, Section V. The 
special features described seem sufficiently safe in and of themselves. 
However, how safe are they if pressure losses or failures are encountered 
In our judgment there should be an expansion of the special features to 
include (1) a back-up or second separate air compressor and distribution 
system, and (2) a separate water pressure and distribution system with an 
air gap between the system and the outside water supply. 
Thank you for the opportunity to review and comment on this document. 
Conservation, Res^rch and Education 
cc: Charles Custard, HEW 
Appendix K — 182 
