Dr. Fredrickson 
-4- 
January 9, 1978 
of a footnote which references such matters as fire, either in the laboratory or 
in other parts of the building, and responses related to natural disasters, such 
as earthquakes or tornadoes. I do not believe this has to be spelled out in 
detail. However, similar to laboratories using radioisotopes, the investigator 
and the institutional representative should be prompted to think through how to 
handle these types of crisis. 
9. AUTOCLAVE LOCATION IN P-3 LABORATORIES- A comment was raised both in 
the letters to you about the guidelines and in the advisory committee meeting 
about the autoclave requirement for P-3 facilities. Should it be in the con- 
trolled area of the P-3 laboratory or should it, as stated in the proposed 
guidelines, "be available in the same building in which organisms containing 
recombinant DNA molecules are used?" From an operational viewpoint, I would 
suggest that the closer the autoclave can be to the point of generation of the 
solid wastes, the more likely we are not to have breaches of this provision 
requiring decontamination of wastes. I am particularly troubled by the term 
"same building," since in our sprawling medical research complexes, often involving 
many hundreds of hospital beds, that could mean transport of wastes a considerable 
distance via some rather sensitive patient areas of the institution. If it is 
inappropriate to require that the autoclave be within the controlled area of the 
P-3 facility, I would suggest some change in wording to reflect a "location con- 
venient and in close proximity" to the controlled area. Even more explicit lan- 
guage would be desirable. 
I hope you will find the above comments of help as you undergo this important 
task of revising the recombinant DNA guidelines. As I am sure is quite evident 
from the early portions of my discussion, the balance of the stringency of guide- 
lines with the realistic assessment of risk (at this point potential risk) will 
place myself and others in similar positions on campuses throughout the country 
in a much more comfortable "environment" in which to implement these guidelines. 
I feel a realistic assessment of risk will help us maintain our credibility with 
the public and outside agencies on the one hand, and with the investigators in 
the various academic units on the other. 
Again, thank you for the opportunity to participate in the process of revising 
the recombinant DNA guidelines. 
Roger L. DeRoos, Ph.D. 
Director 
Department of Environmental 
Health and Safety 
Boynton Health Service 
RLD:mlo 
[Appendix A — 205] 
