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1 observations which form the basis of the need for contain- 
2 ment in the first place, and which should always be at the 
3 beginning of any standards document. Two, a major logical 
4 fallacy which pervades the entire set of documents, in 
5 which the ability to safely perform a process or handle 
5 an organism is confused with the intrinsic hazard of the 
7 organism or process itself. Thus, one can safely handle 
8 iodine 125. This does not mean that iodine 125 is safe. 
9 In fact, to develop safe handling, you have to understand 
10 what will happen if you don't safely handle it. 
11 Three, a heavy reliance on unreferreed, unexamined 
12 reports of small committees meeting in private, which are 
13 then presented as the consensus of the international 
14 scientific community, such as the Ascot report. My own 
15 concern in talking about participation is in the public of 
16 scientists, much broader participation of other NIH-sponsored 
17 scientists. 
18 Four, extraordinary "selectivity" in the documents 
19 in which no arguments which counter or fail to support the 
20 Proposed changes are either quoted or referred to. 
21 To expand on these points, some key observations 
22 whose absence from the documents erodes my confidence in the 
23 RAC: A, in the United States Escherichia coli strains are 
24 the number one cause of community-acquired infections serious 
25 enough to cause hospitalization (Gangerosa, 1978, Journal of 
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