Dr. Fredrickson 
Page 2 
5. A basic premise governing the original containment conditions 
was that all recombinants would initially be handled at a containment 
level much higher than was generally perceived necessary and that, 
with time and experience, these levels would be lowered. I strongly 
endorsed this concept at the Asilomar Conference. At the present 
time, we have had the most experience with recombinants of baker's 
yeast and Drosophila DNA in E. coli cells, and many tests have been 
conducted with them. Every viable DNA sequence of these two eukary- 
otes has been cloned in E. coli , and there is no indication that these 
recombinants pose any possible hazard to man or the environment. 
I think that it is time for recombinants of baker's yeast and Drosophila 
in E. coli K12 to be lowered at least to PI containment. 
6. The present guidelines frequently use the term recombinant DNA . 
The proposed revisions have replaced this term with organisms con - 
taining recombinant DNA . What is generally meant, however, is 
viable organisms containing recombinant DNA . 
7. I strongly disagree with the proposed containment for recombi- 
nant DNA in higher plants. The PI and P2 containment levels were 
designed for microorganisms. How can they be applied to a whole 
corn plant? How can one mouth pipette or generate an aerosol of a 
corn plant? I don't think that higher plants containing non-viral re- 
combinant DNA should require any physical containment at all. 
I was originally a strong supporter of the Guidelines and of the 
processes that generated them. I am no longer such a supporter and, 
in addition, I deeply regret my having been a co-signer of the original 
biohazard letter (Science 185 , 303 (1974)) and a participant in the Asi- 
lomar Conference. I naively thought in those days that a logical proce- 
dure could be set up for generally handling hypothetical hazards that 
would not stifle creativity. I was wrong. The present Guidelines have 
been adequate in administering experiments that were being conducted 
before they were written, but they have been a disaster for new experi- 
ments. Novel experiments that are not explicitly covered in the pre- 
sent Guidelines have generally been prohibited. This prohibition has 
been enacted even though no hazard greater than for those experiments 
presently being conducted was even hypothetically evident. I can only 
conclude that the present Guidelines do not allow for novel and creative 
ideas, and it is not clear that the proposed revised guidelines are an 
improvement. The prohibition of novel ideas and creativity is totally 
[A-160] 
