2 
A revision of paragraph I-D-5 of the revised guidelines is 
required. As written, it does not exclude the possibility of 
giving to some pathogenic organism a drug resistance which it 
might acquire only extremely rarely in nature. The emergence of a 
penicillin-resistant strain of gonorhea was a rare but naturally 
occurring event that has posed serious medical problems. Nowhere 
do the guidelines prohibit the repetition of a similar experiment 
in the laboratory. Section I-D-4, prohibiting the release of 
such an organism into the environment, is not an adequate 
safeguard . 
The educational value of the guidelines (which is important 
in addition to their regulatory value) is hampered by not having 
a clear statement of the dangers of recombinant DNA research. 
In addition, the scientific basis for reductions in containment 
often appear obscure or arbitrary. For example, the contain- 
ment of shotgun experiments with primate DNA has been lowered 
from P4/EK2 to P2/EK2. The rationale for this, stated in the 
director's introduction to the guidelines, is that the possible 
hazards of cloning viral DNA, which is known to be inserted in 
primate DNA, have been re-evaluated and are considered less serious. 
The basis of this was the Ascot workshop on viruses held in 
January 1978. The fact that this conference was open to only a 
carefully selected group of scientists, and that a summary report 
could not possibly consider many of the questions about the safety 
of cloning viruses which were certain to have been raised there, 
is not reassuring. Such critical debates should not be held 
outside the eye of interested participants such as Science for 
the People , union or environmental groups, much less the Recombinant 
DNA Advisory Committee (RAC) , losing here its role in originating 
containment guidelines. Other hazards of experiments on primate 
DNA are not evaluated (5) . 
One possible hazard of recombinant DNA technology, that recom- 
binant organisms can generate autoimmune diseases in humans (6) , 
should be given more attention in a more open scientific forum 
than the Ascot conference. An autoimmune disease might result 
from the exposure of a human protein in an altered state (on the 
surface of a bacterium) and the subsequent activation of a human's 
immune system that might lead it to attack the same protein else- 
where in the same person. A reason for concern is that the human 
intestine does not provide a perfect barrier for proteins which 
might pass through it. It is very likely that mature adults 
regularly absorb macromolecules (proteins) from their intestine. 
A recent scientific study on lactating mothers strongly supports 
this possibility (8): 
"Our clinical findings strongly suggest that some factor or 
factors in cow's milk produces colic in infants. ((Our 
experiments suggest) ) . . . that a macromolecular substance 
eaten by the mother enters her breast milk. There is increasing 
evidence that the normal intestine is permeable to macromolecules 
in quantities that might be antigenic or biologically active (7)." 
[A-371] 
