Dr. Donald S. Fredrickson 
Page 4 
September 22, 1978 
for the handling of whole genomes of transforming viruses. 
It is recommended that the P3-EK1 alternative be allowed 
for section III-A-a-(l). There is no reason to believe 
that experiments with primate DNA would be any more 
hazardous than the handling of the genomic DNA of a known 
tumorigenic virus. 
(6) V. Footnote 1. Classification of Organisms . 
Apparently, there is not yet an updated "Classification 
of Etiologic Agents on the Basis of Hazard" available; we 
retain our concern, expressed earlier, for the misclassifi- 
cation of various actinomycetes . We recommend that the 
members of this order which are pathogens be retained in 
Class 2 with all other thereby being Class 1. The 
commercial importance of several non-pathogenic organisms 
in this group would seem to warrant particular attention 
to this distinction. 
( 7 ) 1 1 -C . Shipment of Materials . 
With regard to shipment of organisms containing 
recombinant DNA, provision should be made to exempt 
well-characterized non-hazardous clones from these 
regulations. Indiscriminate, strict regulation of the 
shipment of all organisms containing recombinant DNA is 
inconsistent with the general relaxation of containment 
requirements for certain experiments. 
The proposed revisions will, in general, do much to 
stimulate needed research in this area. Of particular 
importance are the added opportunities to assess more 
completely questions of safety and the means to further 
minimize risks. We indorse the philosophy of the 
revisions in moving toward relaxation of constraints in 
the absence of evidence for hazards in the conduct of 
various recombinant experiments. The rational continu- 
ation of this process should ultimately lead to a state of 
knowledge commensurate to that which the scientific 
community recognizes in other types of life science 
research for which official guidelines are not required. 
C. W. Pettinga 
rl 
Attachment 
[A-275] 
