-4- 
OBLIGATED TO DIVIDE THEIR TIME BETWEEN SO CALLED BASIC AND APPLIED PROGRAMS 
AND ARE SELDOM FULL TIME GENETICISTS. THEY SIMPLY DO NOT HAVE THE TIME TO 
DO THE EXTRA PAPERWORK AND RESEARCH NEEDED TO CERTIFY THEIR SYSTEMS. FURTHER- 
MORE CONTAINMENT AND SAFETY EQUIPMENT HAS RARELY BEEN NEEDED IN THE PLANT 
SCIENCES SO THAT COMPLIANCE WITH THE GUIDELINES WOULD REQUIRE NEW PURCHASES 
WHICH YOUNG INVESTIGATORS MAY NOT BE ABLE TO AFFORD. IN ADDITION, ESTABLISH- 
MENT OF P2 AND P3 FACILITIES WOULD INFRINGE ON LAB SPACE ORIGINALLY SHARED 
WITH OTHER PROJECTS. 
THE PROPOSED REVISIONS TO THE GUIDELINES SOLVE MANY OF THESE PROBLEMS BY i) 
EXEMPTING OR LOWERING THE CONTAINMENT LEVELS REQUIRED FOR EXPERIMENTS WITH 
SOME OF THE BETTER CHARACTERIZED SYSTEMS, ii) EXEMPTING SELF CLONING EXPERI- 
MENTS AND iii) MAKING PROVISION FOR TRANSFER OF CLONED DNA BACK TO ITS HOST 
OF ORIGIN AT A PI LEVEL. THE ONLY POSSIBLE DIFFICULTY WITH THE REVISED GUIDE- 
LINES THAT HAS COME TO MY ATTENTION IS A GENERAL CONCERN ON THE PART OF 
SCIENTISTS ON JUST HOW MUCH DOCUMENTATION AND THE TIME THAT MIGHT BE REQUIRED 
TO CHANGE THE CLASSIFICATION OF A PARTICULAR EXPERIMENT OR ADD NEW ORGANISMS 
TO THE LIST OF GENE EXCHANGERS. HOWEVER, IT IS COMMENDABLE THAT A MECHANISM 
FOR SUCH CHANGE HAS BEEN PROVIDED. 
IN REFERENCE TO THE EVIDENCE ON WHICH THESE REVISIONS ARE BASED, I AM IN FULL 
AGREEMENT WITH THE RATIONALE SET FORTH BY THE WORKSHOP ON RISK ASSESSMENT OF 
AGRICULTURAL PATHOGENS AND I FEEL THAT THEIR CONCLUSIONS ARE BASED ON SOUND 
PRINCIPLES OF PLANT PATHOLOGY. SPECIFICALLY THEY CONCLUDED THAT INTRODUCTION 
OF DNA FROM PLANT PATHOGENS INTO E. COLI K12 WILL NOT MAKE IT HARMFUL TO MAN, 
ANIMALS OR PLANTS. MOREOVER IT SHOULD BE NOTED THAT RESISTANCE TO MICRO- 
ORGANISMS AMONG PLANTS IS MORE COMMON THAN SUSEPTIBILITY AND THAT FOR AN 
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