UNIVERSITY OF CALIFORNIA, BERKELEY 
• DAVIS • lllVINE • l.OS ANGELES • lUVERSIDF. • SAN DIEGO • SAN FRANCISCO 
SANTA BARBARA • SANTA C1IU7. 
BERKELEY, CALIFORNIA 91720 
COIXKGE OF NATURAL RESOURCES 
agricultural experiment station 
DEPARTMENT OF PLANT PATHOLOGY 
April 13, 1978 
Dr. Donald Frederikson , Director 
National Institute of Health 
Department of Health, Education & 
Welfare 
Bethesda, MD 20014 
Dear Dr. Frederikson: 
On March 20th and 21st, 1978, I participated in the NIH-NSF-USDA workshop 
to discuss risk assessment of agricultural pathogens. Whereas I support the 
recommendations made in our report I want to submit a minority opinion con- 
cerning a recommendation (middle of page 9) of that report, referring to sec- 
tion II. D Biological Containment - Host Vector Systems, a. 2. Other Procaryotes 
(P49600) of the Federal Register. Sept. 27, 1977 part III Draft. Our Committee 
endorsed the La Jolla Working Group Draft. In the event that sections ii i and 
iv are not adopted we proposed that: 
(i) The use of an indigenous plasmid or bacteriophage (vector) shall be 
exempt from the Guidelines. 
(ii) The use of a foreign vector (a non-indigenous plasmid or bacteriophage) 
from an organism which exchanges DNA by natural physiological processes 
shall require P2 containment. 
This distinction is basically similar to the La Jolla Working Group recomendation 
iii. It is not supported by the rationale which was proposed (namely, that: "Many 
seTf-cloning experiments with agriculturally significant bacteria could be more readil. 
and safely carried out by using well characterized £. col i plasmid vectors"). 
t rin nnt sunnnrt. this distinction between indigenous and non-indigenous vectors 
to a laboratory host than to its natural host - tnererore less i .re.y uu ^i ^guo^ 
the recombinant molecules stably in the former case than in. the latter. In either case 
the "self-cloned" recombinant molecules can be expected to integrate into the chro 
[Appendix A — 274] 
