limit requirement. Thus, in granting exemptions, the Advisory 
Committee would be going far beyond the individual cases in question 
to pave the way toward industrial exploitation of the as yet 
immature recombinant technology. This is a critical area which 
requires much study and discussion because of the magnitude and 
scope of its societal and environmental implications. The Advisory 
Committee mechanism, as it is presently operated, is ill-equipped 
to make these broader decisions. Due to its dominantion by academic 
researchers, it may even be unprepared to ask all of the right 
questions. One of the more obvious weaknesses in terms of its com- 
position is the omission of any representatives frcm relevant labor 
unions, (see section on Roles and Responsibilities ) 
One way to avoid the problems of industrial exploitation of 
the recombinant technology in its early stages would be to declare, 
at least temporarily, recombinant DNA organisms to be national resources 
and continue efforts to develop a repository for them. Such a policy 
would ensure that everyone could obtain these organisms for study, 
including representatives from private industry, if proper licensing 
procedures were developed as well. This procedure has been advocated 
by Dr. Marc Lappe, Chief of the Office of Health, Law and Values in 
the California Department of Health. His comments can be found on pages 
32-34 of the Comments booklet. 
Containment Levels for E. Coli hosts 
One assumption in devising containment levels whose factual 
basis is unclear has been carried over frcm the 1976 Guidelines. 
That is that the potential risk is somehow inversely proportional to 
the phylogenetic distance from humans of the source of cloned DNA. 
This is apparently based upon the notion that the more closely related 
the cloned DNA is to humans, the greater the chance of gene expression 
in humans. What is the reasoning behind this? Why is bird DNA somehow 
safer than squirrel DNA? 
(1) The expression of genes in a way that poses a hazard 
may not necessarily be in humans, but in bacteria which 
are infectious, or in plants or other organisms which 
pose a threat other than human infection. 
(2) What about genetic modifications that do not involve 
structural genes, but rather control signals? Is there 
any justification for a phylogenetic effect? 
(3) If the expression of foreign proteins in humans poses 
an immunological risk, then the risk may be greater, 
the more foreign the DNA is. 
(4) Humans are not the sole occupants of this planet. 
The Lowering of Containment Levels by Local Biohazards Committees 
The principle of lowering containments for characterized or 
purefied DNA preparations may or may not be sound; it is difficult 
to judge since we do not '"what went into making this decision. At 
[Appendix A — 190] 
