of the initial guidelines one cannot anticipate in such a rapidly moving 
field, all the advances, opportunities and new information on natural gene 
transfers or of risk assessments. For example, it is not unlikely that B. 
pumulis and ji. subtilis may naturally exchange genetic information. If this 
could be demonstrated, such recombinant DNA experiments should be permitted. 
Thirdly, there are a series of experiments which should be conducted under 
highly controlled (P4) conditions. Recombinant research with class 3 etiolo- 
gical agents are not permitted in spite of the need to explain basic mechanisms 
of pathogenicity with these agents and, in spite of the existence of a national 
P4 facility. Our greatest need is for good risk analysis, particularly with 
class 3 organisms, in which knowledge of genetic systems is scanty and in which 
our own need to develop defensive mechanisms is the greatest. The need, for 
example, to conduct the risk assessments of Dr. W. Rowe with polyoma virus with 
wild type IS. coli is essential in developing national policy. Thus, we believe 
it is important that the Director have such authority, following proper review 
and the availability of an appropriate (P4) facility, to permit such type of 
experiments . 
(5) Roles and Responsibilities 
Our last, but not least, issue concerns the assignment of responsibility. 
For the past two years ve have supported the view that substantial responsi- 
bility be transferred to the IBC. We approve of the recommendations in Section 
IV of the guidelines to implement this goal. For research in the public sector 
we are convinced that license revocation and withholding of Federal funds are 
both sufficient and effective restraints to effect compliance with the guidelines. 
Research in the private sector is not covered by the guidelines and can only be 
corrected by legislation. We note that P>1A, and individual company representatives, 
have committed their organizations to volunteer complicance to Federal guide- 
1 ines . 
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