UNITED STATES DEPARTMENT OF AGRICULTURE 
AGRICULTURAL RESEARCH SERVICE 
PIONEERING RESEARCH LABORATORY 
DEPARTMENT OF PLANT PATHOLOGY 
University of Wisconsin 
MADISON. WISCONSIN 53706 
December 6, 1977 
Dr. Donald S. Fredrickson, Director 
Department of Health, Education, and Welfare 
National Institutes of Health 
Bethesda, Maryland 20014 
Dear Dr. Fredrickson: 
As a research scientist actively working in the field of recombinant DNA, I 
would like to comment on the proposed revision of the NIH Guidelines as they 
appear in the Federal Register no. 187, 49596-49609. I wish to specifically 
address myself to plant pathogens and the manner in which they are handled by 
the Guidelines. Since plant pathogenic nematodes and fungi are not specifically 
discussed in the Guidelines, one can include them with the general group labeled 
lower eukaryotes. However, plant pathogenic bacteria and /viruses appear to be 
special for they are specifically discussed. The following table summarizes 
my interpretation of the revised NIH Guidelines as they pertain to all plant 
pathogens. I have placed plant pathogens into one of four groups for direct 
comparison to the Guideline grouping. The heading. Guideline Group, refers to 
the outline numbers found in the Federal Register: 
Group Plant Pathogen Guideline Group 
Containment 
, lower eukaryotes 
1 
a 
nematodes 
III 
B 
l.a.(l)(e)2. 
P2+EK1 
or 
P1+EK2 ] 
b 
It 
III 
B 
1. c . 
P1+EK1 
2 
a 
fungi 
III 
B 
l.a. (1) (e)2. 
P2+EK1 
or 
P1+EK2 
b 
II 
III 
B 
1. c. 
P1+EK1 
> 
3 
a 
bacteria 
III 
B 
l.a. (2) 
P3+EK2 
b 
It 
III 
B 
l.c. 
P3+EK1 
or 
P2+EK2 
4 
a 
virus 
III 
B 
l.b. (l)(d) 
P3+EK1 
or 
P2+EK2 
b 
It 
III 
B 
l.c. 
P2+EK1 
or 
P1+EK2 
-LJ L U 1 t. I UiVX V J. i- X ' 
) refers to shotgun experiments, b) refers to purified DNA experiments 
It would appear from the table that plant pathogenic bacteria are by far the 
most dangerous plant pathogens with virus next and little concern for fungi or 
nematodes. However, in point of fact, plant pathogenic bacteria and viruses are 
no more dangerous as plant pathogens than fungi or nematodes and, therefore, 
should not be arbitrarily placed in a higher containment level. This inconsis- 
tency in the Guidelines could be eliminated by changing the containment level of 
[Appendix A — 102] 
