- 2 - 
that this would be desirable, why are we so anxious to delete all mention of 
the IBCs from the guidelines? 
Many of the arguments raised in the working ^roup and in RAC depend on 
differences in interpretation of the statement that recombinant DNA is not 
uniquely dangerous. For some, this means that no danger is known or is likely 
to be found; for others, it means that equally hazardous experiments are being 
performed in fields other than recombinant DNA. I think that we all agree 
that some kinds of experiments outside the recombinant DNA field may pose 
dangers similar in scope to those posed by recombinant DNA. response to 
this inconsistency, however, is not to lower our oversight of recombinant DNA 
to the lowest possible level, as RAC has proposed, but to realize that we may 
have built a good, workable system for overseeing research risks, that is worth 
perfecting. 
Ify proposal is much more specific about containment levels than the RAC 
proposal. I have tried to use the same general principles which the RAC 
proposal urges the investigator to use; consider the pathogenicity of the 
host, and what, if any, effect the donor DNA might have. I have chosen to 
be more specific than either RAC or the working group recommendations. If 
we do require IBC oversight, as I am suggesting, I do not think that we do 
the IBCs any favor by removing all specific guidance. At the least, each 
IBC must then make a determination of the appropriate levels of containment 
for a given experiment. This seems an unnecessary waste of time; it is also 
likely to lead to inequities in the application of the guidelines in 
different parts of the country and in different institutions in the same 
cities. Ify proposal therefore sets a reasonable upper limit for containment, 
and allows the IBC latitude in lowering containment where appropriate. 
In summary, I believe that research with recombinant DNA has not led to 
any clearly demonstrable risks, that many experiments are clearly not 
as dangerous as first suspected, and that some- classes of experiments either 
still seem to pose problems or cannot yet be evaluated. We need a filter 
for catching these experiments and letting the others go on in as unencumbered 
a fashion as possible. Revisions of the guidelines over the last five years 
have done much to acheive this goal of focusing on some classes of experiments. 
In the process, the guidelines have become increasingly complex, and we have 
all become increasingly tired of dealing with the complexities. The RAC 
proposal has as its major advantage its appearance of simplicity, but we can 
at least approach that simplicity without sacrificing the useful oversight 
which the guidelines insure. 
I would be happy to discuss my proposal with you in more detail, either 
in the next week by telephone (301-496-3524) or at the 'February RAC meeting. 
I look forward to seeing you there. 
Sincerely 
Susan Gottesman 
[ 762 ] 
