that it is a bit premature to jump to this conclusion at the present 
time. In addition to mere exchange, the possibility for exchange and 
the natural occurrence of exchange should be examined. It is also 
questionable why one should list Escherichia coli exchanges and not 
others in nature such as the organisms that exchange with Bacillus 
subtilis , with Haemophilis influenzae , with Neisseria gonorrhoeae , etc. 
I would therefore advise refraining publishing any list of exchanges 
until it is complete. This will only detract from the urgency to get 
the other exchanges documented as well. 
9. ) The Ascot Conference and the ASM committee reviewing the 
decrease in the level of physical containment for viruses did not have 
the benefit of Dr. Rowe’s recent experiments that were designed to test 
the capacity of Escherichia coli to produce polyoma proteins. Before 
including the reduction in containment levels for viruses I would urge 
that a careful consideration be given to the recent results of Dr. Rowe's 
experiment so that we can have the benefit of his work. 
10. ) I, as well as others will be developing alternate host factor 
systems. It would be very helpful to have the exercise performed for us 
for E, coli K12 even though this is certified as an EV system. To my 
knowledge this has never been done formally. Accordingly, I would urge 
that you give us guidance for the certification of new Hy systems by 
reexamining the E, coli K12 and submitting such a formal certification 
document. 
11. ) As member of the Working Panel for the American Society for 
Microbiology I am concerned with, the possible requirement for certification 
of technicians and individuals who do recomhinant DNA research. You may 
wish to give some thought to this as you evaluate the ASM report. 
12. ) Finally your document is well written ana exceptionally well 
proofed. I only call these few typo’s to your attention to aid you in 
revising any document that you produce. On page 33062, right hand 
column, line 13, word "interpreted" is misspelled. The "i" is missing. 
On page 33071, right hand column, line 16, "decontaminated" is misspelled. 
Finally, on page 33124, middle column, line 12, the word "yery" is 
misspelled. 
Again Don, I wish to compliment you for a job well done. I will be 
sending you under separate cover some information regarding the Bacillus 
subtilis system that I believe should be helpful to you in the final 
evaluation of the guidelines. I wish to get these general comments to 
you as rapidly as possible, however, and will delay the next series of 
comments until I have a chance to put a scholarly document together 
concerning the J3, subtilis system. 
Chairman, Biosafety Co mm ittee 
FEY:dd 
Enc. 
cc Dr. Roger C. Herdman 
Mr. Donald K. Hess 
President Robert L. Sproull 
[Enclosures included (1) New York State bill S. 8019-A, 
Cal. No. 1127, A. 10398-A (Chap. 488, L. 1978, eff. 
7/20/78), and (2) letter from Dr. W.J. Gartland to 
Dr. Frank E. Young, 5/25/78.] 
[A-152] 
