opment Center 
WOOSTER, OHIO 44691 
TELEPHONE (216) 264-1021 
DEPARTMENT OF 
PLANT PATHOLOGY 
September 14, 1978 
TO: HEW Review Committee on Recombinant DNA Guidelines 
FROM David L. Cop 1 in 
Assistant Professor of Plant Pathology 
Ohio Agricultural Research and 
Development Center 
The Ohio State University 
SUBJECT: Summary of comments on proposed revised guidelines for 
recombinant DNA research given at the public hearing 
on September 15, 1978. 
As a plant pathologist, I am greatly concerned that the stringent regulations 
placed on research with plants and plant associated microorganisms by the 
current guidelines for recombinant DNA have greatly delayed the use of this 
technique in such areas as genetic improvement of plants, biological nitrogen 
fixation and the study of plant diseases. Addressing my own area of expertise, 
the cost of plant diseases is tremendously high in terms of crop losses and 
the expense of control measures. Since pesticide usuage is decreasing, there 
is a need , now more than ever, for basic research on plant pathogens so that 
new methods of controlling them can be devised. At present it is not known 
exactly what properties enable only certain specialized pathogens to cause 
plant disease. Physiologists have been handicapped in their approaches to this 
problem due to the lack of good genetic systems to use in identifying virulence 
genes and constructing strains for biochemical studies. Recombinant DNA techni- 
ques now offer an opportunity to study the genetics of plant pathogenic bacteria 
for which usable gene transfer systems have not been developed and to purify 
genes for virulence, work with them in a known genetic background, determine 
their genetic organization and characterize their gene products. This approach 
is much faster, less equivical, and has a better chance for success than by 
doing the same experiments using classical genetic techniques. 
The current guidelines place unnecessarily high containment levels (P2 or P3) 
on recombinant molecules formed from DNA from plants, plant symbionts, and 
plant pathogens (viruses, bacteria and fungi). These restrictions arose from 
unfamiliarity on the part of the authors of the guidelines with these organisms 
and their assumptions that many possibly dangerous plant products are determined 
by single genes and that plant pathogens are equally as infectious and dangerous 
as the animal pathogens found in CDC class 2. This is simply not correct. Other 
problems concerning plant pathogens are the prohibition on restoring virulence 
