Tab A - Page 36 
Mutations In the genes for Ice nucleatlon have been made previously through 
techniques other than recombinant DNA, and naturally occurring mutations. 
Including deletions, happen at low but measurable frequencies In nature. 
Indeed, INA" strains of the bacteria to be used are found In all environments 
and can represent up to 80 percent of all £. syrinqae pv . syrlnqae at a given 
location. Therefore, the recombinant ONA constructed deletion derivative can 
not be considered unique. Under the current Guidelines, the construction of 
such bacteria in the laboratory Is considered a "self-cloning" experiment, and 
therefore is totally exempt from the Guidelines under section III -0-3 . Any 
experiment, however, which proposes to take such an organism out of the 
laboratory, Is no longer exempt from the Guidelines, but rather must undergo 
RAC and NIH review. Therefore, this experiment is exempt for laboratory work, 
but requires RAC and NIH review for field testing. That review, however, has 
recognized that the organism to be tested does not contain a foreign gene and 
is not unique. Therefore, factor (a) in the risk assessment method described 
in Section 5.3. 1A above, should be considered to be zero. 
2. Escape from the Experimental Site 
The probability that at least a few organisms will escape from the test 
plot Is high. The probability that significant numbers of the INA’ bacteria 
will escape, however, is low. The test plot and the possible effects In the 
.event of escape are described below. 
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