Dr. Donald S. Fredrickson 
January 13, 1978 
Page 3. 
to in the guidelines deserve comment. There does not seem to be enough justi- 
fication to require containment levels which are practically unattainable at pres- 
ent for experiments such as the one proposed by Dr. Martin and Dr. Rowe 
(discussed at the December meeting) which is designed to provide much needed 
risk assessment information. Thus, the guidelines appear to be overly restric- 
tive on that end of the scale. At the other end of the scale, the proposed revi- 
sions might be too little restrictive --particularly if one adopts the view that not 
all potentially serious risks have been clearly identified and quantified. The 
situation is complicated by the fact that there appears to be some confusion as 
to which experiments are to be excluded from the guidelines if the proposed revi- 
sions are adopted (i. e. , it is not clear in all instances what is meant by "novel" 
or "not novel" recombinant DNA), as borne out by the statement of Dr. Mary-Dell 
Chilton. If indeed one is to proceed with caution, it would seem appropriate, in 
my opinion, not to exclude such a large number of experiments, but rather to 
modify the guidelines to cover these experiments with a much simplified adminis- 
trative procedure, that is, not only calling for a low physical and biological con- 
tainment level, but also for a low "bureaucratic" containment level; this extension 
of the guidelines should at least provide a more reasonable data basis for future 
revisions. Perhaps a simplification of the administrative procedures is also in 
order for those experiments which call for a Pi containment level under the pro- 
posed revisions. 
There are some additional points which I consider relevant- -points, however, 
that I will not further elaborate upon because they were discussed in sufficient 
detail by other members of the committee. To name a few, I share some of the 
concerns of Ms. Patricia King and Mr. Peter Hutt about procedural matters; I 
agree that appropriate training programs should be established; and I also believe 
that a special effort should be made to communicate to the public some of the 
rather complex technical questions raised by the recombinant DNA issue. 
Sincerely, 
LU UsZ J 
Mario J. Molina 
Assistant Professor of Chemistry 
MJM'.mmg 
[Appendix A — 216] 
