4 
development or improvement of entomopathogenic strains of bacteria for insect 
management has been considered by myself and I have begun some of the basic 
research necessary to facilitate the use of bacteria towards this end. Envisaged 
are possible applications of iji vitro gene splicing and recombinant DNA cloning 
to (1) expand the insect pest host spectrum of existing insect pathogens, (2) 
develop more potent strains of pest insect pathogens, (3) improve the physiological 
tolerance and epidemiological properties of these bacteria, and (4) facilitate 
the in vitro commercial production of the more fastidious insect pathogens by 
expanding the range of substrates upon which they can grow. Two of the present 
organisms with which I am working, Bacillus popilliae , the Japanese beetle 
pathogen, and IJ. thuringiensis , a pathogen of pest caterpillar larvae, both 
enjoy EPA registration and exemption from tolerance in the environment. 
Back in October of 1977 a copy of my proposed recombinant DNA program was 
forwarded to the NIH office of Recombinant DNA Activities for comment and 
clarification of certain aspects of the 1976 NIH guidelines dealing with shotgun 
experiments in procaryotes. Apparently, the NIH Recombinant DNA Advisory 
Committee was unable to come to a definitive decision on the proper containment 
levels for in April, 1978 I received a letter from William Gartland, Director, 
Office of Recombinant DNA Activities (ORDA) suggesting that I submit a draft 
statement for consideration by ORDA on the containment levels for recombinant 
DNA research with entomopathogenic bacteria that have EPA registration. On 
April 24, 1978 I submitted such a statement as requested. 
Although the proposed revised guidelines will simplify the problem of 
interpretation there is still left a rather bothersome issue that may also be 
found in other sections of the guidelines. Under section III-B (Experiments with 
Other Prokaryotic Host-Vectors) host-vector systems which have been approved as 
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