United States 
Department of 
Agriculture 
Animal and 
Plant Health 
Inspection Service 
Washington, DC 
20250 
December 26, 1979 
Dr. Donald S. Fredrickson, Director 
National Institutes of Health 
9000 Rockville Pike 
Bethesda, MD 20014 
Dear Dr. Fredrickson: 
We wish to call to your attention that the proposed guidelines for recombinant 
DNA research (Federal Register 44, No. 232, pages 69210-69251, dated 
November 30, 1979) do not contain any reference to the U.S. Department of 
Agriculture (USDA) permit requirements for the movement of plant pathogens 
across State lines. However, the guidelines do contain a comparable reference 
to animal pathogens (Appendix B, pages 69232-69233). 
It is true that the information about plant pest permits does not warrant 
inclusion in the guidelines on the basis that it is directly related to the 
biohazards of recombinant DNA research. However, it would be a service to 
scientists, particularly if they are not plant pathologists, to be aware of 
their responsibilities under the Plant Pest Act of 1957. 
Under the Act, a permit is required to knowingly move a plant pest across 
State lines. Both State and Federal regulatory officers are involved in 
approving the permit. The permit requirement is in effect whether or not a 
scientist is conducting recombinant DNA research. However, for recombinant 
DNA research, if a scientist wishes, for example, to work with the bean golden 
yellow mosaic virus (page 69222, paragraph III-C-3) , he would need to acquire 
the virus. The virus is not known to occur in the United States except under 
permit for scientific purposes. The scientist should be aware that in order to 
move the virus into his State, he would have to obtain a USDA permit. 
The USDA Recombinant DNA Committee (formerly Joint Council for Food and 
Agricultural Sciences Recombinant DNA Committee) Procedures for intramural 
and extramural research involving recombinant DNA contain the information. 
However, the USDA Procedures would not cover all scientists using plant 
pathogens. 
We suggest that the "Hazard Classification of Plant Pathogens" proposed by the 
Workshop on Risk Assessment of Agricultural Pathogens at a meeting held In 
Washington, D. C. , on March 20-21, 1978, be used in the NIH guidelines in 
Appendix B. The classification was transmitted to you by Dr. Peter R. Day in 
his letter of April 4, 1978. The report was printed in the Federal Register 
as an appendix to one of the NIH guidelines statements. 
In essence we proposed that Appendix B (November 30, 1979, Guidelines and 
Actions) be extended to include after "III, Animal Pathogens (3)," the 
following: 
"IV. Plant Pathogens (3) 
Class 1A Agents - Plant pathogens not in Class IB. 
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